LOCAL DEVELOPMENT FRAMEWORK

Development Polices & Site Allocations

THE PREFERRED OPTIONS REPORT

March 2007

IMPORTANT INFORMATION

WHAT IS THIS REPORT? If you would like to speak to the Planning Policy This is the Preferred Options Report for the Team about the report, you can telephone us Council’s Development Polices and Site on 020 8314 7400. Allocations Development Plan Document (DPD). It contains policies that will be used to HOW CAN I COMMENT? assess planning applications for new We need your feedback on what you think of development and change of use. It also the preferred options presented in this report. contains policies for specific sites and • We want to know what you think? designates certain land for a specific land use • Can improvements be made? e.g. housing, employment etc. • What do you think of the draft policies?

The report provides the detailed planning Comments must be in writing and sent to: policies and builds on the Council’s vision, • Planning Policy spatial strategy and core policies contained in London Borough of Lewisham the document called People, Places and 5th Floor, Laurence House Spaces, the LDFs Spatial (Core) Strategy. At 1 Catford Road, Catford, SE6 4RU; or this stage the policies represent the Council’s • E-mail your comments to: preferred approach it is considering adopting. [email protected] with ‘LDF Development Policies & Site Allocations WHY HAS IT BEEN PREPARED? Preferred Options’ as the subject. New planning legislation required the Council to produce a new set of planning policy The consultation period for the Preferred documents. Collectively these documents are Options Report ends on 13th July, 2007. It is known as the Local Development Framework or important that all comments are received by this LDF. This document is part of the LDF. date. This is to ensure the Council has plenty of time to consider what everyone has said and to WHAT HAS PREVIOUSLY BEEN DONE? move forward to the next stage. The preferred options reflect the findings from the Issues and Options consultation in 2005. WHAT HAPPENS NEXT? This provided the issues, ideas and possible Once the Council has reviewed what the directions for the types of policies and community and stakeholders have said, we will proposals that could apply to development in prepare a final draft document. This will then be Lewisham. submitted to the Secretary of State and be subject to an independent review at an WHO CAN COMMENT ON THE REPORT? Examination in Public, before it can be adopted Everyone can comment. Copies of the report by the Council. are available from: • The Councils website (www.lewisham.gov.uk) PLEASE REMEMBER – ALL COMMENTS • The Planning Service AND RESPONSES SHOULD BE RECEIVED London Borough of Lewisham BY THE COUNCIL NO LATER THAN 5PM ON 5th Floor, Laurence House 13TH JULY 2007. 1 Catford Road

Catford, SE6 4RU • All borough libraries

CONTENTS 1 INTRODUCTION ...... 5 1.1 WHAT IS THE DEVELOPMENT POLICIES AND SITE ALLOCATIONS DOCUMENT...... 5 1.2 PREPARATION OF THE DEVELOPMENT POLICIES AND SITE ALLOCATIONS DOCUMENT ...... 7 1.2.1 What Consultation Has Already Taken Place?...... 7 1.2.2 What Is The Current Consultation About?...... 7 1.2.3 What Will Happen Next? ...... 7 1.3 STRUCTURE OF THIS DOCUMENT...... 8 2 PLANNING PROCESS ...... 10 2.1 THE NEW PLANNING SYSTEM ...... 10 2.2 A FLEXIBLE PLAN ...... 12 2.3 RELATIONSHIP TO OTHER PLANS AND STRATEGIES...... 12 2.3.1 National Planning Policy...... 12 2.3.2 Regional Planning Policy...... 12 2.3.3 Economic Development...... 13 2.3.4 Climate Change...... 13 2.3.5 Local Plans And Strategies ...... 13 2.4 SEA DIRECTIVE AND SUSTAINABILITY APPRAISAL ...... 15 3 DEVELOPMENT POLICIES...... 17 3.1 HOMES FOR ALL (HOUSING) ...... 17 3.1.1 MIX OF HOUSING SIZE ...... 18 3.1.2 AFFORDABLE HOUSING...... 20 3.1.3 CONVERSIONS...... 25 3.1.4 SPECIAL NEEDS AND SPECIALIST HOUSING ...... 27 3.1.5 LIFETIME HOMES AND WHEELCHAIR ACCESSIBLE HOMES ...... 29 3.1.6 GYPSY AND TRAVELLER SITES ...... 30 3.2 SUSTAINABLE MOVEMENT (TRANSPORT AND PARKING) ...... 33 3.2.1 LOCATION AND ACCESSIBILITY...... 34 3.2.2 TRAFFIC MANAGEMENT AND ROAD SAFETY...... 36 3.2.3 PARKING CONTROL...... 38 3.2.4 PROMOTION OF PUBLIC TRANSPORT IMPROVEMENTS ...... 50 3.3 RETAIL AND TOWN CENTRES ...... 53 3.3.1 ROLE AND FUNCTION...... 54 3.3.2 VITALITY AND VIABILITY...... 56 3.3.3 ACCESSIBILITY...... 58 3.3.4 HIGH QUALITY ENVIRONMENT AND DESIGN ...... 59 3.3.5 BOUNDARY ALIGNMENT ...... 60 3.3.6 LOCAL SHOPPING CENTRES AND PARADES ...... 69 3.3.7 OUT OF CENTRE PROPOSALS ...... 71 3.3.8 POLICIES RELATING TO ALL TOWN CENTRES...... 73 3.4 OPEN SPACE AND BIODIVERSITY...... 75 3.4.1 PROTECTION AND ENHANCEMENT OF OPEN SPACE AND AVOIDING INAPPROPRIATE DEVELOPMENT ...... 75 3.4.2 DEALING WITH OPEN SPACE DEFICIENCIES ...... 79

3.4.3 OPEN SPACE PROVISION – QUALITY AND MAINTENANCE ...... 84 3.4.4 PROTECTION AND ENHANCEMENT OF NATURAL HABITATS AND BIODIVERSITY ...... 86 3.4.5 PROTECTION AND ENHANCEMENENT OF OPEN SPACE LINKS AND CORRIDORS ...... 88 3.5 SUSTAINABLE ENVIRONMENT ...... 92 3.5.1 IMPROVING THE USE OF ENERGY ...... 93 3.5.2 PROVIDING FOR RENEWABLE ENERGY ...... 95 3.5.3 FLOOD RISK AND SUDS ...... 98 3.5.4 WATER ...... 102 3.5.5 AIR QUALITY ...... 104 3.5.6 CONTAMINATED LAND ...... 105 3.5.7 NOISE AND LIGHT EFFECT ...... 106 3.5.8 SUSTAINABLE USE OF BUILDING MATERIALS AND AGGREGATES...... 107 3.5.9 HAZARDOUS SUBSTANCES...... 108 3.5.10 WASTE...... 109 3.6 URBAN DESIGN AND CONSERVATION ...... 116 3.6.1 DEVELOPMENT IN CONTEXT AND GOOD URBAN DESIGN ...... 117 3.6.2 TALL BUILDINGS...... 128 3.6.3 THE HISTORIC ENVIRONMENT...... 131 3.6.4 PRESERVATION OF STRATEGIC & LOCAL LANDSCAPE FEATURES ...... 135 3.6.5 LOCAL VIEWS AND LANDMARKS ...... 137 3.6.6 AREAS OF SPECIAL CHARACTER...... 138 3.6.7 RIVER THAMES, DEPTFORD CREEK AND THE RAVENSBOURNE RIVER NETWORK...... 139 3.7 HEALTH, EDUCATION AND COMMUNITY FACILITIES...... 142 3.7.1 NEW SCHOOL SITES AND IMPROVEMENT OF EXISTING SCHOOLS ...... 147 3.8 EMPLOYMENT ...... 149 3.8.1 PROTECTION OF EMPLOYMENT LAND ...... 152 3.8.2 STRATEGIC EMPLOYMENT LOCATIONS ...... 154 3.8.3 LOCAL EMPLOYMENT LOCATIONS...... 166 3.8.4 MIXED USE EMPLOYMENT LOCATIONS ...... 188 3.8.5 OTHER EMPLOYMENT SITES ...... 227 3.8.6 LOCAL LABOUR AGREEMENTS...... 228 4 SITE ALLOCATIONS...... 230

5 IMPLEMENTATION AND MONITORING ...... 325 APPENDIX 1- GLOSSARY OF TERMS...... 328 APPENDIX 2- NATIONAL AND REGIONAL POLICY...... 333 APPENDIX 3- CORE POLICIES / DEVELOPMENT POLICIES / COMMUNITY STRATEGY RELATIONSHIP 338 APPENDIX 4- LIST OF DEVELOPMENT POLICIES AND SITE ALLOCATIONS ...... 342

1. INTRODUCTION

1.1. WHAT IS THE DEVELOPMENT POLICIES AND SITE ALLOCATIONS DOCUMENT? The Government has introduced a new planning system. Councils now have to produce a Local Development Framework or LDF. This is a bundle of documents setting out the Council’s planning policies and strategies. You can see a list of all the plans the Council intends to produce in another document named, the Local Development Scheme, which can be viewed on the Council’s website.

This particular document is the Preferred Options report for Council’s emerging Development Policies and Site Allocations Development Plan Document (DPD) and is structured in two parts: • The development policies provide a set of criteria based policies by which planning applications for new development and change of use will be judged. These policies implement the Core Policies of the LDFs Spatial (Core) Strategy to ensure all proposed development accords with the spatial vision, objectives and strategy for the Borough. • The site allocations identify and designate land for a particular proposal (such as housing, retail, employment, mixed use etc) to ensure sufficient land is available to meet the land use needs in line with the spatial vision, objectives and strategy for the Borough as set out in the Spatial (Core) Strategy.

The report sets out the preferred approach the Council is considering adopting. The draft development policies include criteria that will be taken into consideration by the Council when determining planning applications throughout the Borough. When the Council makes planning application decisions, it will assess and apply the relevant policies in their entirety to the proposal and not just individual policies. In other words, all the policies are inter dependent of each other and should be read in tandem with the policies in the Core Strategy.

Where there are proposals for sites where no specific policy applies, planning applications will be assessed on their individual merits against the spatial objectives of the Core Strategy.

All site specific allocations are set out in this document, except for those set out in Area Action Plans. All preferred options and draft policies should be read in conjunction with the spatial vision, objectives, strategy and core policies detailed in the emerging Spatial (Core) Strategy DPD.

The draft development policies are generally criteria based and focus on issues such as protecting residential amenity; ensuring adequate provision of housing; protection of the landscape and natural resources; nature conservation; addressing highway and transport issues; protecting the viability and vitality of town centres; and addressing visual impact issues.

This document must be prepared in accordance with government legislation and guidance. Primarily this is set out in the Planning and Compulsory Purchase Act (2004). It must

LDF – Development Policies and Site Allocations, Preferred Options Report 5 therefore, take full account of national planning policy guidance and be in general conformity with the regional spatial strategy for London known as the London Plan. The document also undergoes a set of community consultations to involve and take into consideration the wider community in the preparation of the plan.

LDF – Development Policies and Site Allocations, Preferred Options Report 6 1.2 PREPARATION OF THE DEVELOPMENT POLICIES AND SITE ALLOCATIONS DOCUMENT

1.2.1 What consultation has already taken place? The Development Policies and Site Allocations document is known as a Development Plan Document (DPD) in the LDF. The production of a DPD goes through a number of stages and must be in accordance with a document called the Statement of Community Involvement or SCI.

In preparing the relevant documents for the LDF, a scoping report was released for consultation in May 2005, which gauged initial feedback on a range of matters affecting the Borough such as housing, transport, employment and other like. Following on from this, the Council consulted on 12 issues and options papers covering the following topics: • Housing • Waste • Urban Design and Conservation • Sustainable Environment • Open Space • Transport and parking • Economy and employment • Retail and town centres • Education, health and community facilities • Site allocations • Lewisham Town Centre Area Action Plan • Catford Town Centre Area Action Plan

Separate Consultation Reports summarise the responses received and indicates how each response was dealt with. A copy is available from the Planning Service or to download and view from the Council’s website at www.lewisham.gov.uk .

1.2.2 What is this current consultation about? This current consultation presents the preferred options for the range of issues to be covered by the draft Development Polices and Site Allocations DPD. The preferred options have been prepared having regard to: • National and regional policy and guidance • Feedback from the issues and options consultation • Changes that may have been made to Government guidance and planning legislation • The initial and final Sustainability Appraisal of the issues and options and the Preferred Options Sustainability Appraisal and • Other Council documents

In some cases the preferred option has been devised from a combination of the range of options presented at the issues and options stage rather than just one discreet option. The process is broadly illustrated below and highlights the preferred options.

LDF – Development Policies and Site Allocations, Preferred Options Report 7 Scoping Issues & Preferred Options Submission Examination Adoption Report Options in Public

The Council is looking to you, the community and stakeholders, to tell us the following: • What do you think of the preferred options presented? • Can improvements be made to the preferred option? • What do you think of the drafted policy provided? • What about the implementation and monitoring framework?

In some cases the preferred option has been devised from a combination of the range of options presented at the issues and options stage rather than just one discreet option.

1.2.3 What will happen next? After the preferred options consultation, the document will be redrafted taking into account the consultation comments and any changes to Government policy. It will then be subject to further sustainability appraisal and a Submission Development Polices and Site Allocations DPD will be published. As the name implies this document will be submitted to the Secretary of State for an independent examination presided over by a Planning Inspector.

The public and other stakeholders will again have the opportunity to make representations on the submitted document, however, all comments will be submitted to the Secretary of State. The Planning Inspector will make a decision on each representation received. The Inspectors report on the submitted plan will be binding on the Council and any changes recommended in the report must be made before the document is adopted by the Council.

For full details in the consultation process see the Statement of Community Involvement (SCI) which can be obtained from our website or free of charge from the Lewisham Planning Service.

1.3 STRUCTURE OF THIS DOCUMENT The Development Policies and Site Allocations DPD are presented in two parts. Part One comprises the Development Policies and Part Two focuses on Site Allocations.

This Preferred Options Report (Part One) is structured as follows: • Section 1: Introduction explains the role and purpose of the document and the role of the community and stakeholders.

• Section 2: Planning Process explains the document’s relationship to national and regional policy, other LDF documents, other Council studies and documents, and the sustainability appraisal of the preferred options.

• Section 3: Development Policies sets out the preferred options and draft development policies grouped into themes such as housing, transport, design, open space. Each is presented and discussed in terms of the options consulted in the Issues and Options report, the preferred option, the draft policy or policies and the reasons and justification for the preferred approach. The development policies

LDF – Development Policies and Site Allocations, Preferred Options Report 8 provide the detailed implementation of the over arching core policies, contained in the LDFs Spatial (Core) Strategy.

• Section 4: Site Allocations allocates certain land for a specific use and provides a broad development framework for each site.

• Section 5: Monitoring and Implementation outlines the proposed strategy to ensure implementation and delivery of the development policies, and how these will be monitored.

• Appendices provide additional material including further explanation of national and regional policy, relationship of the strategy to the Community Strategy and a glossary.

LDF – Development Policies and Site Allocations, Preferred Options Report 9 2. PLANNING PROCESS

2.1 THE NEW PLANNING SYSTEM Applications for development in Lewisham are currently considered in relation to the policies set out in the Lewisham Unitary Development Plan (adopted July 2004) which regulates all development in the Borough. The current Unitary Development Plan expires in September 2007, therefore the Council will seek to save a number of policies for a further period of three years until the full adoption of the Local Development Framework. The Planning and Compulsory Purchase Act (2004) introduced a new system of plan making in England called the Local Development Framework or LDF. This is radically different from the previous system and has an emphasis on pursuing a sustainable, innovative and productive economy that delivers high levels of employment, and a just society that promotes social inclusion, sustainable communities and personal well being, in ways that protect and enhance the physical environment and optimise resource and energy use.1

The Local Development Framework is a portfolio of planning documents, prepared by the Council, which collectively will deliver the planning strategy for Lewisham. A glossary of all the new planning jargon is set out in Appendix 1. The documents which will comprise the Lewisham LDF are: • Local Development Scheme (LDS) • Development Plan Documents (DPDs), which will include the following documents: o Spatial (Core) Strategy o Development Policies and Site Allocations o Area Action Plans (AAPs) for Lewisham and Catford o The Proposals Map • Supplementary Planning Documents (SPDs) • Statement of Community Involvement (SCI) • Annual Monitoring Report (AMR) • Sustainability Appraisal/SEA directive.

The Local Development Scheme is essentially the work programme for the production of the various documents that make up the LDF. It sets out the name of each document, its purpose and the timetable for its production including the dates of various key milestones.

The Spatial (Core) Strategy is one of four Development Plan Documents (DPD) the Council is preparing. It is the most strategic of the DPDs and sets out the spatial vision and policies for the borough as a whole and its localities. However, it does not identify specific sites. All the other DPDs must be consistent with the strategy and policies set out in the Spatial (Core) Strategy.

The Development Policies and Site Allocations DPD is the document that will set out the main policies that will be used to consider planning applications for development or change of use. This document will contain the more detailed criteria based policies relating to issues such as housing, shops, the design of buildings and car parking. The site allocations part of the document will determine the future land-use of specific sites.

1 DCLG, Planning Policy Statement 1, 2005

LDF – Development Policies and Site Allocations, Preferred Options Report 10

The two Area Action Plan DPDs (Lewisham and Catford Town Centres) will provide the planning framework for the two town centres as they are likely to be subject to significant change in the next few years. The purpose of an area action plan is: • To deliver planned growth • Stimulate regeneration • Protect Conservation Areas and • Focus the delivery of area based regeneration initiatives.

Each of the DPDs has a different but complementary role and together they will provide the comprehensive planning policy framework for Lewisham.

2.2 A FLEXIBLE PLAN The preparation of the Development Plan Document spans a number of years and flexibility is necessary in order to incorporate changes arising from other plans and strategies that may have an impact on the LDF. An example would be the NHS Trust who will have a more direct impact on health matters than the Council. The Trust’s plans and strategies may change over the lifetime of this plan and it is therefore important that there is sufficient flexibility to adapt to new circumstances as they arise.

The Mayor of London is currently consulting on further alterations to the London Plan which includes changes that will have an impact on Lewisham’s LDF. The spatial strategy has been prepared in light of the current London Plan though the Council acknowledges that should the draft alterations be adopted, then the strategy will respond to the adopted document.

2.3 RELATIONSHIP TO OTHER PLANS AND STRATEGIES The preferred options for this DPD have taken into account a range of other plans, strategies and documents at the national, regional and local level and reflect the range of objectives, policies and guidance these documents contain. A summary is provided below.

2.3.1 National Planning Policy Each Lewisham Development Plan Document (DPD) has taken into account national planning policy in formulating the local strategy and policies. The Government has published a number of Planning Policy Statements (PPS) to replace Planning Policy Guidance notes (PPG) which set out the national policies and principles on different aspects of planning. The hierarchy of planning policy is such that the policies set out at the national level must be taken into account by both the regional planning authority (Mayor of London) and the local planning authority when preparing their various LDF documents (see Appendix 2 for a list of national policy documents).

2.3.2 Regional Planning Policy London Plan The Planning and Compulsory Purchase Act (2004) requires the Spatial (Core) Strategy to be in general conformity with the London Plan, that is, the Mayor of London’s spatial strategy for Greater London. The London Plan sets out six objectives, which are: • To accommodate London’s growth within its boundaries without encroaching on open space • To make London a better city for people to live in

LDF – Development Policies and Site Allocations, Preferred Options Report 11 • To make London a more prosperous city with strong and diverse economic growth • To promote social inclusion and tackle deprivation and discrimination • To improve London’s accessibility • To make London a more attractive, well designed and green city.

A summary of the London Plan is provided in Appendix 2. The preferred options for the Development Policies and Site Allocations DPD reflect these objectives and in the Council’s opinion is in ‘general conformity’ with London Plan.

2.3.3 Economic Development The Economic Development Strategy (EDS) produced by the London Development Agency, is the mechanism through which the Mayor of London will deliver the vision of economic development and growth in London. The preferred options for the Development Policies and Site Allocations DPD have taken the EDS into consideration in the development of the relevant options.

2.3.4 Climate Change The effects of climate change can potentially have a seriously damaging effects on the built and natural environment of the borough. An increase in extreme weather conditions will affect biodiversity and habitats and can ultimately alter the species compositions of the fauna and flora. Areas adjoining the river Thames and parts of Lewisham’s river network are of particular concern as they are areas of flood risk.

Efforts to mitigate and adapt to the effects of climate change will be vital for developing a liveable and sustainable environment which will be achieved through the implementation of the development policies. Collectively, these are aimed towards requiring a reduction in resources use, ensuring sustainable construction practices, and linking services and places together to encourage the use of sustainable modes of transport.

This is further reflected in recent draft supplementary guidance released by the Government called Planning Policy Statement 1: ‘Planning and Climate Change’. The draft guidance sets out how spatial planning should contribute to reducing emissions and stabilising climate change (mitigation) and take account the unavoidable consequences (adaptation).

2.3.5 Local Plans and Strategies Community Strategy The Council is part of the Lewisham Strategic Partnership (LSP). This brings together 20 representatives from the public, private, voluntary and community sectors to promote and sustain joint working to secure meaningful ways of engaging the community at all levels, both in terms of setting strategy and delivering modern effective local services.

The LSP developed a Community Strategy with ten key action plans to improve the wellbeing of Lewisham people, develop local communities and improve public sector performance and delivery. It sets out a long-term vision and brings together the many individual strategies from the different agencies and partnerships into one document. These priority areas are the focus of action which will help achieve the vision which is:

LDF – Development Policies and Site Allocations, Preferred Options Report 12 ‘Together we will make Lewisham the best place in London to live, work and learn’

The Development Plans Site Allocations DPD is intended to be the spatial implementation mechanism for the Community Strategy. Appendix 3 shows the relationship between the Community Strategy and each preferred option of the emerging Development Policies and Site Allocations DPD.

Transport and Land-use Land use planning and transport are intrinsically linked in shaping and developing areas in the most effective and sustainable way. The issue of accessibility between home, work, basic services and health education and community facilities is vital in order to reduce traffic related environmental problems such as air and noise pollution and increase connectivity and permeability between spaces and places.

The Lewisham Local Implementation Plan (LIP) is a statutory document required by the Mayor of London to show how the Borough will implement the Mayor’s Transport Strategy. This needs to be consistent with the London Plan, the Mayor’s spatial strategy . The LIP outlines how movement through the borough will be managed via local transport policies, the transport network and strategies for future development. The Development Polices and Site Allocations DPD has integrated the key considerations of the LIP to specific development policy and are detailed in the preferred options section of this report.

Air Quality The urban environment is a major contributor to air pollutants that affect human health and the natural environment. Industrial activity, construction and road traffic emit the majority of these pollutants. This has led to the designation of air quality management areas in urban areas and along busy roads. The Air Quality Management Area (AQMA) in Lewisham is in the north of the borough where the air quality objectives are not likely to be met for NOx (nitrogen oxide) and PM10 (Particulate Matter up to 10 micrometers in size).

The AQMA is the main area for growth in the borough and it is essential that air quality is addressed on a strategic level. The Spatial (Core) Strategy aims to reduce vehicle journeys and distance travelled by locating development close to existing public transport links and areas where public transport will be improved; making homes, jobs, basic services and health, education and community facilities more accessible.

The SELCHP (South East London Combined Heat and Power) waste incineration plant is the only Part A 1 process in the borough and is regulated by the Environment Agency.

The implementation of the Development Polices and Site Allocations DPD aims to reduce vehicles journeys and distance travelled by ensuring development is located close to existing public transport links and areas where public transport will be improved; and making homes, jobs, basic services and health, education and community facilities easily accessible.

Other local plans and strategies A number of local plans and strategies have been adopted by the Council. The Development Polices and Site Allocations DPD have taken these into consideration, and reflect and

LDF – Development Policies and Site Allocations, Preferred Options Report 13 implement relevant objectives and strategies. The following is a list of the local plans and strategies that have been reviewed: • A Safer Lewisham (2005-2008) • Climate Change Strategy (2006) • Early Years Development and Childcare Implementation Plan • Economic Development Business Plan • Education and Development Plan (2002-2007) • Health in Equalities Strategy (2004 - 2010) • Lewisham Creative Lewisham – Lewisham Cultural and Urban Development Commission • Lewisham Contaminated Land Strategy (2001) • Lewisham Energy Policy (2001) • Lewisham Environmental Policy (2002) • Lewisham Homelessness Review and Homeless Strategy (2003-2006) • Lewisham Housing Commission, Final Report (2000) • Lewisham Housing Strategy (2004 – 2007) • Lewisham Local Air Quality Action Plan (2003) • Lewisham Local Implementation Plan (2005 – 2010) • Lewisham Municipal Waste Strategy • Local Biodiversity Plan – A natural renaissance for Lewisham • Local Cultural Strategy • Open Space Strategy for Lewisham (2005 – 2010) • School Organisation Plan for the London of Lewisham (2004 – 2009) • Skills for Life Strategy (2002 – 2010) • Social Inclusion Strategy 2005 – 2013 • Teenage Pregnancy, Parenthood and Sexual Health Strategy (2001 – 2010).

2.4 SEA DIRECTIVE AND SUSTAINABILITY APPRAISAL Government guidance (PPS12) requires Development Plan Documents to be subject to strategic environmental assessment to comply with European Union directive 2001/42/EC. The requirement to meet the SEA directive has been met by incorporating the required criteria to the ‘Environmental impacts’ element of the Sustainability Appraisal (SA), which will be applied to all Development Plan Documents and Supplementary Planning Documents.

The purpose of the Sustainability Appraisal is to assess the social, economic and environmental effects of strategies and policies in a local development document. This has been applied to each preferred option and draft core policy. The Sustainability Appraisal process is integrated with the plan production process so that sustainability issues are fully considered from the outset and the public is informed.

The methodology for producing the Sustainability Appraisal includes an appraisal of the impact of national and regional plans and strategies and this again ensures that the impact of these policies is included in the preparation of the DPDs. Where policies or proposals do not initially meet sustainable objectives and are likely to have an adverse affect, they have been withdrawn, replaced, modified or mitigation measures introduced. The sustainability assessment has made the following key changes to the preferred options in the

LDF – Development Policies and Site Allocations, Preferred Options Report 14 Development Policies and Site Allocations DPD (full details of all changes made are provided in the SA report):

Homes for all (Housing) Affordable housing target has been set at 35% rather than 50% as suggested by the mayor for London. The target was reduced due to the long term negative impacts on the SA objective on economic growth, which is caused by the relatively low land values in the borough. A higher affordable housing target may make new development proposals less economically viable and hence negatively affect the housing target and economic growth.

Sustainable Movement (Transport and Parking) Minor changes were made to the wording and sentence structure of some of the policies.

Retail and Town centres The SA appraisal highlighted that the policy on ‘Types of uses in Core, Non- Core and Other shopping Areas (Excludes Lewisham and Catford Town Centre’ (RTC2)) had only a small positive effect on the SA objective on Transport. This was improved upon by adding a requirement for green travel plans. The change would put emphasis on the use of sustainable modes of transport which would contribute to making town centres more accessible and hence improve potential for economic growth.

Open Space and Biodiversity The policy on biodiversity was improved by adding ‘public access and appreciation of biodiversity’ as an enhancement measure, which can be required from developers. This change resulted from the SA objective on education which showed long term positive impacts if the policy was revised. The improved policy would enable new areas for wildlife to thrive giving local people the opportunity to learn about biodiversity in Lewisham. The policy itself does not actively seek to educate the public but through conservation and protection management measures, a new role in educating the public to the wildlife in the borough could be an indirect benefit. A new policy on open space quality and maintenance (OS5) was added to strengthen the SA objective for landscapes and townscapes.

Sustainable Environment The SA process highlighted that policies on energy efficiency, sustainable construction, water, flood risk, and climate change showed positive impacts on biodiversity, energy efficiency, water retention, and reducing the heat island effect. A new policy on living roofs was subsequently added to cover all these issues. The policy on construction and demolition waste was strengthened to require the reuse of a minimum of 10% of this waste in the construction process.

Urban Design and Conservation The policy on Development Sites – Trees, Landscape Planting and Nature Conservation (UD4) makes specific mention of living roofs which was included as it showed positive impacts for a number of SA objectives, such as biodiversity, flood risk, energy efficiency, and water.

LDF – Development Policies and Site Allocations, Preferred Options Report 15 Health, Education and Community Facilities Minor changes were made to the wording and sentence structure of some of the policies.

Employment land The SA objectives related to social concerns and employment identified that large new developments would generate opportunities for work, which could benefit local people and hence improve the local economy. Consequently a new policy on local labour agreements was created which will enable local people to access local training and work opportunities in large new development sites.

Site Allocations The changes made to the site allocations preferred options have been detailed in the SA report.

The Sustainability Appraisal report is published alongside the Development Policies and Site Allocations DPD for public consultation. A copy is available from the Planning Service or online from the Council’s Planning Policy website at www.lewisham.gov.uk.

LDF – Development Policies and Site Allocations, Preferred Options Report 16 3. DEVELOPMENT POLICIES

3.1 HOMES FOR ALL (HOUSING)

Overview The planning system is the key tool by which all levels of government seek to increase the level of housing. The provision of new homes is vital to meeting the housing need of the community. Throughout England, the Government is committed to promoting sustainable patterns of housing development. This can be achieved through concentrating most additional housing within urban areas; making efficient use of land; adopting a sequential approach to the allocation of land for housing and managing the release of housing land.

Relevant housing issues for development control include: • The mix of new housing in terms of dwelling size • The need to provide affordable housing • The number and type of dwellings that are converted to provide additional housing • The need for special forms of accommodation to meet local need and • Gypsy and Traveller sites.

A summary of the responses received from the issues and options consultation, the relationship of this topic to the Community Strategy, and the preferred options for each issues are detailed below.

Issues and Options Consultation The main responses on the housing topic from the Issues and Options consultation were:

• There was concern over increased housing targets and the pressures this would place on infrastructure and the new demand for facilities, especially health, education and other community and leisure services. • There needs to be recognition that the nature and size of new housing will create different needs, especially for services and facilities - social and family housing will generate more needs. • There is a need to integrate and relate any new housing to existing residential areas. • There is a need to recognise that the greatest housing demand is from the social rented sector. • There is a need to provide key worker housing. • There was support for housing mix policies if applied broadly or to affordable housing. • Conversions should be permitted subject to a threshold on the size of the dwelling to be converted. • There was support for the retention of the current affordable housing policy, while the GLA supported a lower threshold to ensure greater provision. • There was support for the concept of mixed and balanced communities, however, decisions should be made on a case by case basis. • There was support for the provision of special needs and specialist housing subject to controls to ensure there is not a concentration in one area. • There should be limits to the amount of housing required to be built to Lifetime Homes standards.

LDF – Development Policies and Site Allocations, Preferred Options Report 17 Relationship to the Community Strategy The Community Strategy deals with the economic, social and environmental well-being of the Borough and seeks to improve the quality of life in Lewisham. It has been prepared by the Lewisham Strategic Partnership in consultation with the London Borough of Lewisham. As such it deals with a range of public service issues well beyond the remit of the Local Development Framework. Nevertheless, consultation with local people on the Strategy has revealed a high level of concern about issues that are central to the LDF.

The main areas in which housing supports the borough’s Community Strategy is through investment in current Council stock and working in partnership to provide new, affordable homes, which supports the Strategy’s action of Regeneration (secure the sustainable regeneration of Lewisham, its housing, transport and environment); as well creating mixed and balanced communities, which contributes to social cohesion and can help make Lewisham a safer place.

HOUSING ISSUES

3.1.1 MIX OF HOUSING SIZE Housing mix refers to the size (usually in number of bedrooms) of new or converted housing in both market housing and affordable housing. Planning policies have sought to influence the size of housing so that housing needs can be met in terms of matching house sizes to household sizes. This can contribute to the objective of achieving mixed and balanced communities so that housing within any area caters for a range of households, from single persons through to large families.

The Options Four options were put forward as part of the Issues and Options consultation. 1. Set a preferred housing mix for affordable housing. 2. Set a preferred housing mix for market housing. 3. Set a broad mix for all housing. 4. No housing mix policy.

The Preferred Option The preferred option is to proceed with option 1 and apply option 2 and 3 for market housing.

Draft policies

H1 Housing Mix – Affordable Housing Affordable housing developments of 10 or more dwellings will be required to provide where practicable, the following overall housing size mix: Dwelling Size/Tenure Social Rented Housing Intermediate Housing 1 bedroom 35% 45% 2 bedroom 40% 45% 3 bedroom 15% 10% 4 bedroom 10%

LDF – Development Policies and Site Allocations, Preferred Options Report 18

H2 Housing Mix – Market Housing For market housing, the Council will seek an appropriate mix of dwellings within a scheme, having regard to the following criteria: a) the physical character of the site or building and its setting; b) the previous or existing use of the site or building; c) access to private gardens or communal garden areas for family units; d) the likely effect on demand for car parking within the area; e) the surrounding housing mix and density of population; and f) the location of schools, shops and open spaces.

Reasons for the preferred option Consistency with National and regional planning guidance The need to plan for a mix in affordable housing is supported in PPS3: Housing. Developers should brig forward proposals for market housing which reflect demand and the profile of households requiring market housing, in order to sustain mixed communities. Proposals for affordable housing should reflect the size and type of affordable housing required (paragraph 23).

The mix of accommodation in the Borough should be related to a range of household types and address deficiencies in the range of accommodation. The provision of a mix of dwelling sizes will provide opportunities for existing residents to stay within the Borough as their accommodation needs change and assist in creating communities that are balanced and sustainable by providing greater choice in the range of housing types, styles and tenures.

The London Plan at Policy 3A.4 (Housing choice) seeks to ensure that all new housing developments offer a range of housing choice in terms of housing sizes and types based on local needs. The required mix for market housing developments are in accordance with the GLAs Housing SPG 2005.

The preferred option supports the GLAs Greater London Housing Requirements Study (December 2004) which identified the number of dwellings necessary to meet current and future housing requirements across the region. Further recent research from the GLA (Size Matters, The need for more family homes in London, June 2006) reiterates that a successful affordable housing policy is not just about the amount secured, but it is also about meeting the needs of an area in terms of suitability.

Consistency with other Council documents The Lewisham Housing Needs Survey (2003) (LHNS) suggests the main shortfall is for three bedroom dwellings. This is broadly reflected in market housing, except there is a shortage in the borough of house sizes of more than three bedrooms when compared against household sizes of more than four persons. The housing mix percentage requirements indicated in the draft policy were derived from Table 9.3 of the LHNS.

LDF – Development Policies and Site Allocations, Preferred Options Report 19 What alternatives were considered and why were they rejected Options 2 and 3 were combined to better reflect national and regional guidance. Option 4 does not support national and regional guidance.

3.1.2 AFFORDABLE HOUSING In accordance with national and regional policy and guidance, the Council expects private developers to make a contribution towards the provision of affordable housing in Lewisham. Affordable housing is defined as housing designed to meet the needs of households whose incomes are not sufficient to allow them to access decent and appropriate housing in their borough. Affordable housing comprises social housing, intermediate housing and in some cases, low-cost market housing. When being sold it is generally housing costing 3.5 times the household income (between £16,400 -£49,000). The corresponding definitions from PPS3: Housing, are:

• Social housing: rented housing owned and managed by local authorities and registered social landlords, for which guideline target rents are determined through the national rent regime. The proposals set out in the Three Year Review of Rent Restructuring (July 2004) were implemented as Policy in April 2006. It may also include rented housing owned or managed by other persons and provided under equivalent rental agreements to the above, as agreed with the local authority or with the Housing Corporation as a condition of grant. • Intermediate housing: housing as prices and rents above those of social rent, but below market price or rents, and which meet the criteria set out above. These can include shared equity products (e.g. HomeBuy), or other low cost homes for sale and intermediate rent. • Market housing: owner-occupied and private rented housing, which does not meet the affordability and access criteria for social housing or intermediate housing.

Despite the average property price for November 2006 in Lewisham (£245,070) being well below the Greater London average (£304,912) affordability remains an issue (Land Registry, Residential Property Price Report, November 2006). Owner occupation is becoming an increasingly difficult goal to achieve. Over 15,000 people are currently awaiting offers of social housing (Housing Directorate, London Borough of Lewisham) with a shortfall existing between the demand for affordable housing and supply.

The key affordable housing policy issues include the: • Thresholds which determine when an affordable housing contribution is sought; • Amount of affordable housing provided as part of a development proposal; • Tenure mix of affordable housing; and • Need to create mixed and balanced communities.

Related to these issues, particularly the first three, is the economic viability of housing development when affordable housing needs to be included as a component.

Affordable housing thresholds are the levels of housing development on any site above which planning policy will require a contribution to affordable housing. The amount of affordable housing is the number of dwellings to be provided on site (in total) where a site is

LDF – Development Policies and Site Allocations, Preferred Options Report 20 developed for market housing. The tenure of affordable housing refers to the type of affordable housing, whether it be social rented and/or intermediate.

The provision and tenure of affordable housing has a significant impact on the creation of mixed and balanced communities and through the application of affordable housing policy the Council has the opportunity to assist in the creation of more mixed and balanced communities at a local level. In various parts of the borough the tenure mix is dominated by social rented housing, while in others, owner occupied and the private rental market are more dominant. Social rented housing makes up 35.6% of all housing in the borough, however, ward variations see some locations above 40% (Bellingham 46.3%, Downham 43.6%, New Cross 52.9%, Telegraph Hill 44.2%) with Evelyn ward containing 70.2% of social rented housing.

The Options The following options were put forward as part of the Issues and Options consultation. Thresholds: 1. To seek a contribution to affordable housing on sites capable of providing more than 15 dwellings or sites of more than 0.5 hectares. 2. To seek a contribution to affordable housing on sites capable of providing more than 10 dwellings. 3. To seek a contribution to affordable housing on all residential sites.

Amount: 1. To seek, as a starting point for negations, a contribution of 20% of affordable housing. 2. To seek, as a starting point for negotiations, a contribution of 35% of affordable housing. 3. To seek, as a starting point for negotiations, a contribution of 50% of affordable housing. 4. To seek, as a starting point for negations, 50% of affordable housing as part of large housing developments.

Tenure and the creation of mixed and balanced communities: 1. Affordable housing contribution of 70% social rented and 30% intermediate across the whole borough. 2. Only intermediate affordable housing in areas with high social housing. 3. Facilitate ‘off site’ social rented housing. 4. Focus social rented housing in areas with currently low representation. 5. Make decisions case by case. 6. As part of an intermediate contribution, seek key worker housing.

The Preferred Options The preferred options are as follows: 1. Thresholds: Combination of options 1 and 2 but with a lower land size threshold. 2. Amount: option 2. 3. Tenure and Mixed and Balanced Communities: option 1 and a combination of options 2, 3 and 6.

LDF – Development Policies and Site Allocations, Preferred Options Report 21 Draft Policies

H3 Affordable Housing: Thresholds and Amount Where a development site is capable of accommodating 10 or more dwellings or is 0.3 hectares or more, the Council will seek to secure 35% of new private residential build as affordable housing.

H4 Affordable Housing: Tenure The required affordable housing tenure mix will be 70% social rented and 30% intermediate provision delivered across private sites. Developer’s would be required to demonstrate a mechanism for retaining affordable housing in perpetuity.

H5 Creating Mixed and Balanced Communities Where a site falls within an area which has existing high concentrations of social rented housing, the Council will seek, in agreement with developers, for any affordable housing contribution to be provided in a way which assists in securing a more balanced social mix within that locality in order to establish and sustain ‘viable balanced communities’. This would include more flexible tenures such as ‘part ownership’ and other shared equity schemes or other types of arrangement as considered appropriate. ‘Cash in lieu’ payment will not normally be accepted by the Council.

Reasons for the preferred options The preferred option retains the UDPs affordable housing target of 35% (for new private residential development), however, the provision of affordable housing would apply to sites capable of accommodating 10 or more dwellings, reduced from the current 15 or more dwellings. There would also be a requirement to negotiate affordable housing on sites 0.3 hectares. This has been reduced by a third from the existing 0.5 hectares as the dwelling threshold has been reduced by a third.

The lower thresholds combined with retaining the 35% target would result in a higher percentage of affordable housing being delivered from private development than what currently occurs under the UDP. The tenure mix would adopt the London Plan position of 70% social rented and 30% intermediate provision, however, exceptions would be considered where there are high concentrations of social rented housing to ensure mixed and balanced communities.

A. Thresholds and amount: Consistency with National and regional planning guidance The Government and the London Plan both seek to ensure the planning system delivers the maximum amount of new housing. PPS3 recognises that the community’s need for affordable housing is a material planning consideration, which should be taken into account in formulating development plan policies and in determining planning applications involving housing. The type and amount of affordable housing should be identified by the Council based on the housing needs of the borough. Suitable developments for affordable housing include new build, as well as mixed-use schemes where the unit threshold is exceeded; live- work schemes; and residential conversions from commercial premises.

LDF – Development Policies and Site Allocations, Preferred Options Report 22 In setting a local affordable housing target Policy 3A.7 (Affordable housing targets) of the London Plan requires boroughs to take account of regional and local assessments of needs and the London wide strategic target where 50% of all new housing provision should be affordable (from all sources). While Policy 3A.8 (Negotiating affordable housing in individual private residential and mixed-use schemes) seeks a reasonable amount of affordable housing for private developments which would encourage rather than restrain development.

The preferred option is for a 35% threshold from private residential development. This figure excludes affordable housing provided by a Registered Social Landlord (RSL). In 2005/06 six planning applications were received for schemes of 15 dwellings or more or on sites over 0.5 hectares. This resulted in the provision of 246 affordable dwellings (LBL Development Control 2005/06).

The 35% contribution from private developers is further supported through a report released in March 2003 titled ‘Thresholds for application of affordable housing requirements’ which was prepared by the Three Dragons, Nottingham Trent University, Roger Tym and Partners and Eiluned Morgan. This report was prepared and published for the GLA and the Government Office for London and was commissioned to examine the viability of the 50% affordable housing target. The report recommended that in a borough such as Lewisham a 35% affordable housing target would be more readily achievable. This is due to the lower house prices experienced when compared with the London average and the associated lower than average returns from development. It is unlikely that many schemes could remain viable if required to meet additional costs and achieve close to the 50% London Plan affordable housing target. This approach could undermine the borough’s ability to meet housing provision targets.

The Council therefore considers it pragmatic to seek a contribution of 35% of the residential content from private developers. The figure presents a reasonable balance between meeting Lewisham’s need for affordable housing whilst not undermining the viability of private housing development. It is achievable and realistic.

Consistency with other Council documents According to the Lewisham Housing Needs Study (LHNS) Lewisham has a level of current need which is above average and a level of projected need which is well above average. On the basis of these figures the Council could, in theory, be justified in seeking 100% affordable housing, but this is not the role of the planning system. However, the LHNS does support the lower threshold of 10 dwellings which would contribute to meeting housing need.

What alternatives were considered and why were they rejected For thresholds, options 1 and 2 have been combined to ensure affordable housing provision covers the widest number of sites. Option 3 was dismissed as it would not be economically sustainable.

For the amount of affordable housing, option 1 was dismissed as it is well below the requirements of the London Plan, as was option 4, which would only require a contribution as part of large housing developments. Option 3 is not considered economically sustainable.

LDF – Development Policies and Site Allocations, Preferred Options Report 23 For tenure and the creation of mixed and balanced communities, options 1, 2, 3 and 6 have been combined to ensure affordable housing provision covers the widest number of sites and is in accordance with national and regional policy and guidance unlike options 4 and 6 which were the least sustainable.

Other planning reasons The lower threshold of 10 dwellings or more combined with retaining the 35% target would contribute to the provision of a higher percentage of affordable housing in the borough. In 2005-06, 25 planning applications were granted approval for 10 or more dwellings. Of this, 19 planning applications were between 10 and 14 units which equated to 229 dwellings. If the 35% affordable housing provision was applied, this would have created an additional 80 affordable housing dwellings. Although such schemes have lower profit margins than larger schemes, the London housing market may offer enough profit to justify prescribing that some of these units are provided as affordable. The Council could seek an element of affordable housing on these sites, an approach which is being pursued by several London boroughs and is endorsed by the Greater London Authority.

A 10-14 unit scheme requiring the provision of 35% affordable housing would generate 3 to 4 affordable units per scheme. Provided on site, they would encourage mixed and balanced communities. However registered social landlords have indicated that it is not always viable to have small numbers of affordable units scattered but prefer units in one location. The Council could, where appropriate, seek a payment for off-site provision.

B. Tenure and mixed and balanced communities: Consistency with National and regional planning guidance PPS3: Housing (paragraph 20) states that key characteristics of a mixed community are a variety of housing, particularly in terms of tenure and price and a mix of different households such as families with children, single person households and older people. The Council considers it should not be obliged to require additional social housing in locations where there is already an ‘over-provision’ of that tenure. The diversification of tenure in new housing development is a means of generating a more viable and sustainable mix of households.

The London Plan at Policy 3A.7 (Affordable housing targets) suggests affordable housing should be supplied as 70% social rented and 30% intermediate housing. The GLAs Housing SPG (November 2005) indicates that boroughs should establish locally the required tenure balance based on housing needs studies, an assessment of capacity and potential supply and the provision of mixed and balanced communities. It also indicates that in boroughs which have a high proportion of existing social housing that the provision of higher levels of intermediate housing would assist in achieving mixed and balanced communities.

The London Housing Strategy 2005-16 indicates that London has an uneven spatial distribution of socio-economic groups, potentially damaging to social cohesion. The strategy aims to encourage more mixed neighbourhoods in terms of income, economic activity, tenure and household size to assist in the creation and maintenance of more sustainable communities.

LDF – Development Policies and Site Allocations, Preferred Options Report 24 Consistency with other Council documents An analysis of non-owning households by the LHNS demonstrates that social rented housing is the sub-tenure that is most capable of meeting the great majority of housing need in the Borough. Based on this analysis the Council’s preference is for the provision of social rented housing except in those areas which already have high concentrations of this sub-tenure. It would not be possible in this context to achieve the objective of mixed and balanced communities and estate renewal without a greater focus on providing more housing for sale.

The wards of Bellingham, Downham, Evelyn, New Cross and Telegraph Hill are identified as areas of the Borough where over 43% of ward households live in social-rented housing. The Borough average is 36%. The preferred option seeks in areas where there is more than 43% social rented housing, the affordable housing provision required will be sought in a way which assists in securing a more balanced social mix within that locality. This may take the form of more flexible tenures including ‘part ownership’ and other shared equity schemes as considered appropriate for the delivery of affordable housing. This approach supports the government’s objective of creating mixed and balanced communities.

What alternatives were considered and why were they rejected Options 4 and 5 were dismissed as they would not contribute to the objective of mixed and balanced communities, do not meet local housing need nor provide an adequate local policy basis or support national and regional policy and guidance.

3.1.3 CONVERSIONS Conversions refers to converting the use of an existing building from one use to another use. This primarily involves larger family dwellings being converted into a number of smaller dwellings, usually flats. Conversions have been a valuable source of housing supply in Lewisham and demand for conversions is expected to continue. The key planning issue is whether conversions are appropriate, particularly if larger family dwellings are lost.

The Options Four options were presented for the Issues and Options consultation: 1. Allow conversions. 2. Allow conversions only for houses that have a net floor space of 130m2 or more as originally constructed. 3. Allow conversions but require at least one family dwelling to be provided. 4. Do not allow conversions.

The Preferred Options The preferred option is a combination of options 1, 2 and 3.

LDF – Development Policies and Site Allocations, Preferred Options Report 25 Draft Policies

H6 Conversion of Residential Property The permanent conversion of larger dwelling houses into two or more self-contained units will be considered subject to consideration of the following criteria: (a) The scheme results in the provision of an increase in suitable accommodation; (b) The size of the dwelling house to be converted is not less than 130 square metres net as originally constructed; (c) Suitable family accommodation is provided as part of the conversion in the form of a dwelling with three or more bedrooms; (d) The character of the buildings or neighbourhood or the amenities of neighbouring properties is not adversely affected; (e) The safe movement of emergency and refuse vehicles or other essential traffic, and pedestrians, is not adversely affected by additional on-street parking; (f) The dwelling is not a house in multiple occupation (HMO) which provides a satisfactory standard of accommodation for those who need short term relatively low cost accommodation; and (g) Sufficient area of the original garden is retained and provides an adequate setting for the converted building and enough private open space for the use of the intended occupants.

Reasons for the preferred options Consistency with National and regional planning guidance PPS3: Housing, seeks to meet housing need and to increase the supply of new housing. Conversions, however, present potentially conflicting objectives. While additional housing is created, this can be at the loss of larger family dwellings which are required to meet housing need. Both objectives seek to achieve the wider objective of mixed and balanced communities.

The preferred option supports housing provision as outlined in the London Plan and the London Plan SPG for Housing. The Council recognises the value of private gardens to provide a refuge for wildlife and provide people with access to the natural environment. The Mayor of London expects that biodiversity and wildlife habitat will be taken into account in proposals for the development of garden land.

Consistency with other Council documents LB Lewisham carried out a Housing Needs Assessment in 2003 which concluded that the Borough suffers from a shortage of larger housing units (particularly 3+ bed units) and a mismatch between household size and the general size of dwelling. It is for this reason that the draft policy seeks to retain small family units and to provide family units (of 3 bedrooms or more) as part of any conversion.

Whilst it is clear that there is a shortage of larger housing units, the need to protect this form of housing is very much focussed towards preventing conversion of small family houses, rather than promoting the redevelopment of sites to provide a mix of unit types (unless the site can accommodate 10 or more units).

LDF – Development Policies and Site Allocations, Preferred Options Report 26 Ensuring the retention of the original garden and use of private open space suitable for the intended occupants supports the Lewisham Biodiversity Action Plan.

What alternatives were considered and why were they rejected Combining options 1, 2 and 3 as the preferred option ensures consistency with national and regional guidance, contributes towards housing demand and aims to ensure that conversions, while recognised for their contribution to the total housing provision in Lewisham, are sufficiently controlled so as to reduce adverse effects on the residential amenity of the immediate neighbourhood and contribute to the supply of family housing. Option 4 was dismissed as it would not contribute to these objectives.

Other planning reasons In a primarily residential borough like Lewisham, the potential for additional residential dwellings of one or two bedrooms through conversion of the existing dwelling stock continues to come forward. Analysis of past trends shows the supply of this sort of housing remains a significant source of additional dwellings and meets the London Plan requirements

In order to promote housing choice, the Council must balance the demands for one and two bedroom units with the need for family housing. A family dwelling suitable for households including children, usually consists of 3 or more bedrooms and the minimum size of 130 square metres is considered appropriate and adequate to accommodate this form of household. It is therefore important that the stock of family housing is retained to help meet residents’ aspirations to stay within the Borough throughout their life cycle.

3.1.4 SPECIAL NEEDS AND SPECIALIST HOUSING The provision of special needs and specialist housing is a key requirement of the planning system. The provision of special needs housing is vital in order to meet the needs of the whole community. Special needs and specialist housing is specifically designed to meet the needs of the community that cannot be met through traditional self-contained housing. This can include although is not limited to: • Older people • People with physical and sensory disabilities • People with a learning disability • People with mental health problem • Vulnerable young people and children needing care and • Students.

The Council’s aim is to facilitate provision of a full range of accommodation including that provided with an element of social or medical care. The suitability of a site for the provision of special needs and specialist housing will be determined by the proximity of essential local shops and facilities within walking distance, easy access to public transport, and in some cases the topography of the site.

LDF – Development Policies and Site Allocations, Preferred Options Report 27 The Options Two options were considered for consultation as part of the Issues and Options. 1. To encourage the provision of special needs housing. 2. To encourage the provision of special needs housing but ensure that surrounding land uses are considered so that a concentration of such housing is not created.

The Preferred Option The preferred option is option 2, which carries the Council’s current approach and contributes to the objective of mixed and balanced communities by ensuring there is not a concentration of this form of housing within any given residential area.

Draft policy

H7 Specialist and Special Needs Housing Specialist and special needs housing falling within classes C2 and C3 of the Use Classes Order will need to: (a) Meet a proven local need (for example by being within the approved forward plans of a relevant health and/or social service agency); (b) Provide accommodation in a location and of a type that is well designed to meet the needs of the particular client group; (c) Be accessible to local shopping facilities, public transport and amenity space; (d) Include accommodation for any residential staff in accordance with relevant requirements; (e) Be larger than 130 square metres net as originally constructed, if it is a change of use; and (f) Have regard to the existing distribution of similar types of accommodation within the area to avoid a concentration.

Reason for the preferred option Consistency with National and regional planning guidance The preferred option is supported by national and regional policy and guidance. PPS3 seeks to ensure that a full range of housing need is met. Policy 3A.10 (Special needs and specialist housing) of the London Plan seeks to ensure that special needs and specialist housing, including sheltered housing with care support staffed hostels and residential care homes, is provided in order to meet the housing needs of the community. This is reinforced in Policy 3A.13 (Loss of hostels, staff accommodation and shared accommodation) where the loss of such housing and specifically hostels, staff and shared accommodation, should be resisted if it meets an identified need.

Consistency with other Council documents The LHNS found that those with special needs are more likely to be living in unsustainable housing, therefore adequate provision is essential. The preferred option also contributes to the implementation of the Council’s Supporting People strategy.

LDF – Development Policies and Site Allocations, Preferred Options Report 28 What alternatives were considered and why were they rejected Option 2 is the preferred option as this contributes to the objective of mixed and balanced communities by ensuring there is not a concentration of this form of housing within any given residential area in order to protect the character and amenity of the local environment. For this reason option 1 was dismissed.

3.1.5 LIFETIME HOMES AND WHEELCHAIR ACCESSIBLE HOMES Lifetime Homes are defined as ordinary homes designed to provide accessible and convenient housing for a large segment of the population from young children to frail older people and those with temporary or permanent physical or sensory impairment. Lifetime Homes have 16 design features that can be universally applied to housing design to ensure that the home will be flexible enough to meet the existing and changing needs of most households, as set out in the Joseph Rowntree Foundation report ‘Meeting Part M and Designing Lifetime Homes’.

Part M of the Building Regulations deals with accessibility for housing. Lifetime Homes standard adds to the regulation with requirements which seek additional built in flexibility so that housing can better meet the needs of the community. Lifetime Homes include features such as doorways and hallways designed to allow wheelchair access and fixtures and fittings at heights useable for all. These design features help make the homes ‘universal’ in their appeal and application while providing residents with many advantages.

Wheelchair accessible housing refers to homes built to the standards set out in the National Wheelchair Housing Group report Wheelchair Housing Design Guide 1997.

The Options Four options were put forward as part of the Issues and Options consultation. 1. Require all housing to meet lifetime home standards. 2. Require all housing in major developments to meet lifetime homes standard. 3. Require 10% of all new housing to be wheelchair accessible or easily adapted for those using a wheelchair. 4. Require 10% of all new housing in major developments to be wheelchair accessible.

The Preferred Option The preferred option is to proceed with options 1 and 3. It is further considered that where developers indicate that not all the 16 points of the Lifetime Homes requirements are achievable, the case could be set out in an access statement.

Draft Policy

H8 Lifetime homes and wheelchair accessible homes All new residential dwellings should be built to Lifetime Homes Standards and 10 per cent of all new dwellings should be wheelchair accessible or easily adapted for those using a wheelchair. This includes all new build, conversions and flatted development.

LDF – Development Policies and Site Allocations, Preferred Options Report 29 Reasons for the preferred option Consistency with national and regional planning guidance PPS3: Housing requires that local planning authorities provide a greater choice in housing types and to provide housing which meets the needs of all in the community.

The London Plan at Policy 3A.4 (Housing choice) relates to housing choice and encourages boroughs to ensure that all new housing is provided to lifetime homes standards and that 10% of new housing is designed to be wheelchair accessible or easily adapted for those using a wheelchair. This is further supported through the London Plan SPG, Accessible London: Achieving an inclusive environment.

Consistency with other Council policy documents The preferred option contributes to the implementation of the Council’s Supporting People strategy.

What alternatives were considered and why were they rejected Option 2 for lifetime homes has been dismissed as it would only apply to major developments. The preferred option for wheelchair accessible housing supports the London Plan while option 4 has been dismissed as it would only apply to major developments.

Other planning reasons Meeting Lifetime Homes standards is considered a cost-effective way of providing homes that are adaptable, flexible, convenient and appropriate to changing needs. They enhance choice, enable independent living and help create more mixed and balanced communities.

It is considered reasonable to apply the preferred option to all new housing. This includes conversions and refurbishments, flatted development for both social housing and private sector housing; with the relevant housing catering for a varying number of occupants. The Joseph Rowntree Foundation estimates that in addition to their added value in adaptability and sustainability, building to Lifetime Homes standards adds one per sent or less to a scheme’s development costs with substantial savings made longer term. Firstly, because Lifetime Homes are cheaper to adapt as needs change and secondly, the independent living they enable is significantly cheaper, and preferable , than the alternatives of hospitalisation or care homes.

It is sometimes argued that some of the 16 Lifetime Homes components are more difficult to achieve than others, namely parking adjacent to the property and ground floor living rooms, which do not easily fit in with the nature of higher density flatted development. In such circumstances it is considered that applicants would need to justify the variance through an access statement.

3.1.6 GYPSY AND TRAVELLER SITES The Government defines Gypsies and Travellers as:

‘a person or persons who have a traditional cultural preference for living in caravans and who either pursue a nomadic habit of life or have pursued such a habit but have ceased travelling, whether permanently or temporarily, because of the education needs of their

LDF – Development Policies and Site Allocations, Preferred Options Report 30 dependant children, or ill-health, old age, or caring responsibilities (whether of themselves, their dependants living with them, or the widows and widowers of such dependants), but does not include members of an organised group of travelling show people or circus people, travelling together as such’ (ODPM Circular 01/06).

The Council currently operates a site in Thurston Road near Lewisham Town Centre. The 2002 Lewisham Housing Needs Survey did not review the housing needs of gypsies and travellers. The level of demand for sites will be confirmed through further consultation with relevant representative groups and work currently being undertaken by the Greater London Authority.

The Options One option was put forward for consideration as part of the Issues and Options consultation. 1. Set out criteria for assessing new gypsy and traveller sites.

The Preferred Option Government guidance outlines that the housing needs of Gypsies and Travellers is an issue that should be considered when formulating planning policy as part of the LDF. Given the release of Circular 01/06 Planning for Gypsy and Traveller Caravan Sites, it is considered that the only option to pursue in the spatial strategy is criteria based policy when considering new sites.

Draft Policy

H9 Gypsy and Travellers The Council will continue to assess and provide for the identified needs of Gypsy and Travellers in appropriate locations.

Gypsy and Travellers sites will be assessed against the following criteria: (a) It is accessible to local shops, services and community facilities in particular schools and health services; (b) It has safe and convenient access to the road network; (c) It has provision for parking, turning, service and emergency vehicles and servicing of vehicles; (d) The activities do not have an adverse impact on the safety and amenity of occupants and their children and neighbouring residents particularly in terms of noise and overlooking, and other disturbance from the movement of vehicles to and from the site; (e) It has a supply of essential services such as water, sewerage and drainage and waste disposal; and (f) It is designed and landscaped to a high standard.

Reasons for the Preferred Option Consistency with national and regional planning guidance Circular 01/06 ‘Planning for gypsy and traveller caravan sites’ requires boroughs to consult with gypsy’s and travellers in order to ascertain what their needs and intentions are in order to determine if site provision is adequate. However, it is the regional planning authorities

LDF – Development Policies and Site Allocations, Preferred Options Report 31 responsibility to undertake the Gypsy and Travellers Accommodation Assessment required by the Circular. In London this means the Mayor of London.

Circular 01/06 Planning for Gypsy and Traveller Caravan Sites provides updated guidance on the planning aspects of finding sites for gypsies and travellers and how local authorities and gypsies and travellers can work together to achieve that aim. The preferred option reflects this guidance.

The London Plan Policy 3A.11 (London’s travellers and gypsies) requires that boroughs work together to assess the accommodation needs of gypsies and travellers and review capacity. The Council should also protect existing sites, set out criteria for identifying new sites and identify when shortfall occurs. The Mayor is currently in the process of undertaking a Pan- London study to identify gypsies and travellers needs and seek the identification of sites. Following the release of the Pan-London needs study the LDF will include relevant criteria and allocate new sites if and where there are shortfalls. In the interim, in order to identify a site there is a need to establish criteria. The preferred option covers various criteria in order to address amenity issues of the site and those it surrounds.

What alternatives were considered and why were they rejected Government guidance outlines that the housing needs of gypsies and travellers is an issue that should be considered when formulating planning policy as part of the LDF. Given the release of Circular 01/06 Planning for Gypsy and Traveller Caravan Sites, it is considered that the only option to pursue in the spatial strategy is criteria based policy when considering new sites.

LDF – Development Policies and Site Allocations, Preferred Options Report 32 3.2 SUSTAINABLE MOVEMENT (TRANSPORT AND PARKING)

Overview Transport and parking are crucial elements for a sustainable environment. Car traffic in particular contributes to congestion and air pollution with consequent effects on the economy, health and quality of life. The preferred options presented seek to deal with ways of integrating development with public transport; protecting and improving public transport; the Council’s approach to new road building and traffic management; providing for the needs of pedestrians and cyclists; and car and cycle parking standards.

A summary of the responses received from the issues and options consultation, the relationship to the Community Strategy, and the discussion on each preferred option is detailed below.

Issues and Options Consultation The main responses on the transport and parking topic from the Issues and Options consultation were:

• There was support for higher density development where good public transport is available. • Walking and cycling improvements and facilities should be considered as part of all new development in order to achieve sustainable transport. • There was strong support for the Council to require a transport assessment and a (green) travel plan for certain development. • There was a desire to see local streets designed for local traffic and not as through roads - roads are not just for motorised vehicles and should be designed to reduce vehicle speed to a minimum. • The walking distance to public transport, the cycle network and distance to schools should be included as a criteria to assess accessibility. • There was support for developers to contribute to public transport infrastructure where deficiencies are identified. • There is a need to retain the railway corridors as nature areas. • Developers should have the option of promoting car free residential development in areas with excellent public transport facilities. • There was mixed response in terms of car parking standards. There was both support for retaining the current UDP standards and for the adoption of the London Plan standards. • There was a strong desire to see improvements to all forms of public transport.

Relationship to the Community Strategy The Community Strategy deals with the economic, social and environmental well-being of the Borough and seeks to improve the quality of life in Lewisham. It has been prepared by the Lewisham Strategic Partnership in consultation with the London Borough of Lewisham. As such it deals with a range of public service issues well beyond the remit of the Local Development Framework. Nevertheless, consultation with local people on the Strategy has revealed a high level of concern about issues that are central to the LDF.

LDF – Development Policies and Site Allocations, Preferred Options Report 33 Action Plan 2 of the Strategy discusses the need to sustain and improve the health and wellbeing of local people. The LDF can help deliver the LSP action of promoting sustainable modes of transport such as walking and cycling.

Action Plan 6 of the Strategy discusses the need to ensure Lewisham has the transport infrastructure to underpin its social, economic and environmental ambitions. The LDF can help deliver the LSP action of ensuring Lewisham has the transport infrastructure to underpin its social, economic and environmental ambitions, by contributing to the targets of: • Increasing light rail use (measured by passenger journeys) by 2010 • Improving air quality • Reducing road congestion • Promoting integrated transport solutions and investing in public transport and the road network and • Increasing the number of journeys made by walking and cycling.

TRANSPORT AND PARKING ISSUES

3.2.1 LOCATION AND ACCESSIBILITY The location of all forms of development and the traffic and people movement associated with that development is a key consideration of government planning guidance and underpins sustainability objectives of the emerging LDF. The aim is to locate the facilities and services people need (jobs, schools, housing, shopping, entertainment and the like) in places which reduce the need to travel, especially by private car.

The Options Six options were put forward as part of the Issues and Options consultation. 1. Allow higher density development only in places where good public transport is available and restrict development in places with poor public transport. 2. Require transport assessment/travel impact statements for all new developments. 3. Set thresholds for development that will be required to submit travel impact statements. 4. Require green travel plan for large scale developments or developments which will generate a ‘significant’ amount of movement. 5. Require developers to contribute to public transport infrastructure where deficiencies are identified. 6. Require developers only to meet the immediate transport improvements related to their development.

The Preferred Option The preferred option is to proceed with options 1, 5 and 6 and proceed with options 2, 3 and 4 with amendments.

LDF – Development Policies and Site Allocations, Preferred Options Report 34 Draft Policies

T1 Location of development Major trip generating developments must be located where: (a) Opportunities for public transport use, walking and cycling are maximised; or close to where this can be provided as part of the proposal; and (b) The need for car use is minimised.

Improvements to the transport system required for the development to proceed will be secured through a condition or planning obligation on a planning permission.

T2 Development and accessibility (a) Major trip generating developments will be required to provide a Transport Assessment to be submitted with a planning application to assess the likely travel movements by all modes and their impact on congestion, safety, and the environment of the surrounding area. The scope of the assessment will reflect the scale of the development proposed and the extent of the transport implications. (b) A travel impact statement would normally be accompanied by a travel plan. (c) Mitigation measures identified in the Transport Assessment will be secured through a condition or planning obligation on a planning permission.

T3 Travel plans (a) Developments that will have a significant transport implication will be required to submit a travel plan in order to reduce the impact of travel and transport on the environment. (b) The implementation of a travel plan will be secured through a condition or planning obligation on a planning permission.

T4 Transport infrastructure In appropriate circumstances, planning obligations will be sought for: (a) Highway improvements or traffic management measures, which are necessary for a development to proceed; and/or (b) Public transport improvements to services or facilities; and/or (c) Other measures to improve accessibility by pedestrians and cyclists.

The cumulative impact of a development will also determine if and when planning obligations are sought.

Reasons for the Preferred Option Consistency with national and regional planning guidance PPS3: Housing seeks to reduce car dependence by ensuring proposed development is easily accessible and well connected to public transport.

PPG13: Transport seeks to promote more sustainable transport choices, accessibility to jobs, shops and services as well as reducing the need to travel. PPG13 promotes the use of travels plans for a range of development types which generate a significant level of travel demand, including employment, retail, leisure, education and health uses. Travel plans are

LDF – Development Policies and Site Allocations, Preferred Options Report 35 useful tools to ensure that a development minimises adverse environmental consequences of the travel demand it may generate. As such they contribute to meeting sustainability and traffic reduction targets.

The London Plan encourages the integration of transport and development by encouraging patterns and forms of development that reduce the need to travel and by supporting high trip generating development only at locations with high public transport accessibility and capacity. Travel impact statements and travel plans are supported as are planning obligations for transport infrastructure. The preferred options support London Plan policies 3A.5 (Large residential developments), 3C.1 (Integrating transport and development), 3C.2 (Matching development and transport capacity), 3C10 (Phasing of transport infrastructure), 6A.4 (Priorities in planning obligations) and 6A.5 (Planning obligations).

Consistency with other Council documents The Lewisham Local Implementation Plan (LIP) is a statutory plan to implement the London Mayor’s Transport Strategy. The actions set out in the LIP are supportive of implementing a sustainable transport strategy particularly with regard to the location of new development.

What alternatives were considered and why were they rejected Each option is being pursued (albeit in modified or consolidated form) as they support and implement sustainability and local objectives and government legislation.

Other planning reasons Land uses and transport must be integrated. The existing network of public transport should be fully exploited in the interests of efficiency and maximising accessibility. It is appropriate that where developments will make significant demands on public transport their scope for contributing to public transport provisions should be assessed. Developers will be expected to liaise with the Council to determine an appropriate transport strategy for the scheme. Travel assessments can assist in securing sustainable development compatible with wider objectives.

3.2.2 TRAFFIC MANAGEMENT AND ROAD SAFETY Traffic management is not just about managing traffic flow; it should recognise that people movement is important and should be given priority over the car. Traffic management should aim to: • Reduce congestion within the Borough • Establish clear priorities for sustainable transport options and • Encourage more sustainable transport choices.

Allocation of street space should reflect the priority given to more sustainable forms of transport. By managing traffic and reducing congestion the number of vehicles on the road can be reduced, which will contribute to safer and healthier environments. For the 2001- 2011, the Mayor of London aims to reduce weekday traffic by 15% in central London and achieve zero growth across inner London.

LDF – Development Policies and Site Allocations, Preferred Options Report 36 The Options Two options were put forward as part of the Issues and Options consultation. 1. Manage and distribute traffic in accordance with the road hierarchy established in the Unitary Development Plan. 2. Introduce engineering, education and enforcement measures to improve road safety.

The Preferred Option The preferred option is to proceed with both options.

Draft Policies

T5 Street hierarchy The Council will manage the use of streets by establishing the street hierarchy as set out on page 52 consisting of Strategic Roads, London Distributor Roads, Local Distributor and Local Access Roads.

T6 New road building and improvements New road building will be kept at a minimum and new road schemes and improvements to existing roads will be supported where they: (a) Are consistent with the needs of public transport operators, cyclists, pedestrians, safety requirements and local planning objectives; (b) Primarily serve other purposes such as regeneration; major public transport improvements; and/or wider traffic management programmes; and (c) Allow traffic to be reassigned from unsuitable roads in the hierarchy.

The effectiveness of the use of roads should be measured in terms of the number of people moved rather than vehicles. There should be a general presumption in favour of pedestrians, cyclists and buses in the allocation of road space.

T7 Traffic management The Council will introduce traffic calming schemes and measures in appropriate locations so as to: (a) Reduce traffic to achieve the role assigned to roads in the hierarchy; (b) Allocate road space to essential traffic and environmentally friendly modes of transport; (c) Reflect the requirements of land uses along the road, in terms of access, essential movement and environmental needs; (d) Improve the environment for residents; and (e) Take account of the needs of public transport operators.

A planning obligation may be sought for off-site traffic mitigation measures to address potential adverse traffic impacts arising from a development proposal.

T8 Freight (a) Road freight movements should be restricted and confined to suitable routes in accordance with the road hierarchy in order to protect residential amenity.

LDF – Development Policies and Site Allocations, Preferred Options Report 37 (b) Rail and water borne transport of freight will be encouraged with relevant freight operators where such use does not compromise the amenity of neighbouring uses or adversely affect the water environment and air quality.

Reasons for the Preferred Option Consistency with national and regional planning guidance PPG13: Transport recognises that priority should be given to people over ease of traffic movement and that traffic management should be undertaken in a way which complements the wider planning and transport objectives; including reducing noise, air pollution and traffic accidents, promoting safe walking, cycling and public transport, and helping to reduce congestion pressures.

The London Plan discusses the need to reduce congestion and make better use of London’s streets through road scheme proposals, allocation of street space and local area transport treatments. The preferred options support London Plan policies 3C.15 (Road scheme proposals) to 3C.18 (Local area transport treatments).

The Government initiative Transport 2010 aims to reduce the number of people killed or seriously injured in Great Britain in road accidents by 40% and the number of children killed or seriously injured by 50% (compared with the 1994-98 average); and aims to halt the deterioration in local road conditions by 2004 and eliminate the backlog by 2010.

Consistency with other Council documents The preferred approach is consistent with the objectives in the Lewisham Local Implementation Plan (LIP). The LIP is a statutory plan to implement the London Mayor’s Transport Strategy. The LIP includes proposed actions for traffic management proposals in town centres and area schemes and sets out a road safety plan for the borough.

What alternatives were considered and why were they rejected Both options are being pursued as they support and implement sustainability and local objectives and government legislation.

Other planning reasons New road construction can help meet movement needs but at a financial and land use cost. A complementary approach is to make the best use possible of existing roads by defining and structuring their use accordingly. Road building alone does not relieve congestion, it just provides for otherwise restrained demand and is therefore unsustainable. The presumption should be in favour of better management of the available road space.

3.2.3 PARKING CONTROL Parking control performs an important role in influencing people’s behaviour and travel patterns. National and regional guidance strongly urges local authorities to restrict the amount of parking in both residential and commercial areas and avoid the over provision of parking to encourage people to choose more sustainable modes of transport which contributes to a healthier more pleasant environment. However, it is important for the Council to recognise and balance the needs of the community against environmentally sustainable objectives to ensure accessibility and social inclusion.

LDF – Development Policies and Site Allocations, Preferred Options Report 38 Local authorities are encouraged to seek alternative methods of parking control in order to restrict the amount of parking. The Council will need to investigate alternative parking control measures (such as shared car parking, car-free residential development and ‘Home Zones’) as a means of contributing to sustainable transport options.

The Options Nine options were put forward as part of the Issues and Options consultation. 1. Continue to use the UDP Car parking standards for new development proposals. 2. Adopt the London Plan standards for car parking. 3. Introduce some other car parking standards. 4. Require specific cycle provision as part of all developments. 5. Negotiate cycle provision on an individual basis. 6. Promote car-free residential development in areas with excellent public transport facilities. 7. Insist on some minimum parking provision in relation to all residential development. 8. Extend the provision of controlled parking zones (CPZs). 9. Require developers to contribute towards the implementation of CPZs.

The Preferred Option The preferred option is to proceed with options 2, 3, 4, 6, 8 and 9.

Draft Policies

T9 Traffic management The Council will introduce traffic calming schemes and measures on the road network and in adjoining areas so as to: (a) Reduce traffic to achieve the role assigned to roads in the hierarchy; (b) Allocate road space to essential traffic and environmentally friendly modes of transport; (c) Reflect the requirements of land uses along the road, in terms of access, essential movement and environmental needs; (d) Improve the environment for residents; and (e) Take account of the needs of public transport operators.

A planning obligation may be sought for traffic mitigation measures to address potential adverse impacts arising from a development proposal.

T10 Home zones The Council supports the principle of Home Zones and 20 MPH zones and will investigate the experimental introduction of such and similar traffic management schemes so that optimum solutions can be found.

T11 Car free residential development The Council will support car free development provided that: (a) There is very good public transport accessibility; and (b) Developers can demonstrate that the development will have no adverse impact on on- street car parking.

LDF – Development Policies and Site Allocations, Preferred Options Report 39 T12 Controlled Parking Zones The Council will review the existing controlled parking zones (CPZs) and will consider introducing new CPZs particularly in and around: (a) Town Centres; (b) Railway stations; and (c) Other high traffic generating land uses.

Proposals which adversely affect on street parking may be required to contribute to the introduction of a CPZ and a planning obligation may be sought to secure funding.

T13 Car parking standards The Council will normally require development to make provision for off-street parking in accordance with the standards set out in Table 1. New development shall: (a) Provide conveniently located spaces designate for the use by people with disabilities; (b) Where appropriate, encourage multiuse parking, including the public use of private commercial car parking spaces; and (c) Have regard to the level of public transport accessibility.

T14 Provision for cyclists The Council will only grant planning permission for development where it makes satisfactory provision for cyclists. In assessing development, traffic management and highway alterations, the Council will seek to: (a) Provide a network of well signposted cycle routes throughout the borough; (b) Provide suitable and safe cycle routes to schools and on commuter routes which contribute to the London-wide strategic cycle route network; (c) Take account of the needs of cyclists in the design of highway improvement schemes; and (d) Provide secure, attractive, convenient and adequate cycle parking and changing facilities in the borough's town centres, at public transport interchanges and on business, residential and leisure development sites.

The Council will require development to make provision for cycle parking in accordance with the standards set out in Table 1.

A planning obligation may be sought for cycling measures arising from a development proposal.

T15 Motorcycle parking The Council will normally require development to make provision for motorcyclists and allocate parking space in appropriate development.

T16 Pedestrian routes and access The Council will seek to ensure that: (a) New developments; and (b) Traffic management, highways alteration and parking schemes,

LDF – Development Policies and Site Allocations, Preferred Options Report 40 provide safe and convenient routes and access for pedestrians which, provide links to public transport.

A planning obligation may be sought for pedestrian measures arising from a development proposal.

Reasons for the Preferred Option Consistency with national and regional planning guidance PPG 13: Transport seeks to promote more sustainable transport choices, accessibility to jobs, shops and services as well as reducing the need to travel. To deliver this objective, the guidance recognises that parking policies can be used to promote sustainable transport choices and reduce the reliance on the car for work and other journeys.

The car parking standards do not require developers to provide more spaces than they wish; encourage the shared use of parking; avoid creating disincentives for developers to locate away from town centres; require developers to provide designated disabled parking spaces; and require convenient safe and secure cycle parking.

The London Plan recommends maximum parking standards for broad classes of development. Maximum standards should be used to promote sustainable transport choices. The preferred options support policies 3C.22 (Parking strategy) and 3C.23 (Parking in town centres).

Consistency with other Council documents The LIP sets out a Parking and Enforcement Plan for the borough. This sets out details of the operational policies including proposed CPZs how the Council proposes to enforce its parking policy.

Cycling will be promoted in the Borough and the Council will work with relevant agencies to maintain and provide free cycle carriage on rail and promote cycle use of bus lanes. The needs of cyclists will be pursued in all new development, road and traffic management schemes.

What alternatives were considered and why were they rejected Option 1 was dismissed as parking standards need to be updated, reflect current government policy and achieve sustainable transport objectives. Option 2 is part dismissed as the Council believes there are specific characteristics for Lewisham which need to be listed. Option 3 is part dismissed as the London Plan has more restrictive parking standards for certain land uses than what current provision would permit. Restrictive parking provision could depress economic performance, contribute to illegal parking or parking in undesirable areas or displace vehicles to neighbouring areas with less restrictive parking standards. Option 5 was dismissed as cycling is a sustainable transport mode and all developments should provide cycle parking in accordance with clear guidance.

LDF – Development Policies and Site Allocations, Preferred Options Report 41 Table 1. Lewisham Car Parking Standards

Please refer to the notes at the end of the table for an explanation of the standards and terms used.

Use Class Description Parking Standard Cycle Parking Detail (Maximum) RETAIL A1 Food stores up to 500m2 1 space per 35-50m2 Town centre/local Customer parking may be considered (PTAL 2 to 4) centre: 1 space per unnecessary in certain locations. Under 1 space per 75m2 125m2 such circumstances planning obligations (PTAL 5 to 6) (Source: UDP) will be sought for transport improvements. (Source: London Plan) Out of centre: 1 space per 350m2 Food supermarket up to 1 space per 20-30m2 (Source: UDP) 2500m2 RFA/4000m2 GLA (PTAL 2 to 4) 1 space per 30-45m2 (PTAL 5 to 6) (Source: London Plan)

Food superstore over 1 space per 18-25m2 2500m2 RFA/4000m2 GLA (PTAL 2 to 4) 1 space per 25-38m2 (PTAL 5 to 6) (Source: London Plan) Non food warehouse 1 space per 30-50m2 Town centre/local Customer parking may be considered (PTAL 2 to 4) centre: 1 space per unnecessary in certain locations. Under 1 space per 40-60m2 300m2 (includes such circumstances planning obligations (PTAL 5 to 6) garden centres) will be sought for transport improvements. (Source: London Plan) Out of centre: 1 space per 1500m2 with minimum of 4 spaces (Source: UDP)

LDF – Development Policies and Site Allocations, Preferred Options Report 42 Use Class Description Parking Standard Cycle Parking Detail (Maximum) Shopping mall/complex in 1 space per 35-50m2 Suggesting: town centre (PTAL 2 to 4) 1 space per 300m2 1 space per 50-75m2 (PTAL 5 to 6) (Source: London Plan) A2 Financial and Professional Nil 1 space per 125m2 Headquarters-style buildings of financial (Source: London Plan) with minimum of 2 buildings and high street banks, building spaces societies etc., should be treated as B1 (Source: UDP) offices. A3 Restaurants & Cafes Nil 1 space per 20 seats (Source: London Plan) (Source: UDP) A4 Drinking establishments Nil 1 space per 100m2 (Source: London Plan) (Source: UDP) A5 Hot food takeaways Nil 1 space per 50m2 (Source: London Plan) (Source: UDP) BUSINESS B1 (a) Offices 1 space per 600-1000m2 1 space per 125m2 B1 (Source: London Plan) with minimum of 2 spaces (Source: UDP) B1 (b), (c) Research and 1 space per 600-1000m2 1 space per 500m2 Associated office space will be treated as B2 and B8 development, light (Source: London Plan) (Source: UDP) offices for parking requirements. industry, general industry, Parking must take account of minimum warehousing, storage and operational needs. wholesale distribution Developments that operate HGVs as part of their business or anticipate deliveries by HGVs must provide at least one HGV space. Sui Generis Builders merchants, car 1 space per 600-1000m2 1 space per 500m2 Some Sui Generis uses are considered sales, rental, service and (in addition to any vehicle (Source: UDP) acceptable in employment locations. repair garages display areas) Parking standards are required to resist the over supply of parking for customers on such sites.

LDF – Development Policies and Site Allocations, Preferred Options Report 43 Use Class Description Parking Standard Cycle Parking Detail (Maximum)

RESIDENTIAL C1 Hotels including boarding To be determined on an Appropriate taxi ranks and coach/bus Hotels houses and guest houses individual basis using a parking stands will be required as part of transport assessment and the Transport Assessment. travel plan to support the level of parking. (Source: London Plan) C2 Residential To be determined on an Residential schools/colleges individual basis using a institutions transport assessment and travel plan to support the level of parking. (Source: London Plan) C3 Houses: Detached/ 1.5-2 spaces per dwelling 1 space per house Dwelling houses Semi Detached (Source: London Plan)

Terrace houses 1-1.5 spaces per dwelling 1 space per house (Source: London Plan) Flats 1 to less than 1 space per 1 space per flat flat (Source: London Plan) Other Residential Live/Work As per Class B uses with It may be appropriate to reduce parking in 1 space per unit for the locations with good access to public residential component. transport. Children’s Homes, Elderly 1 space per 4 resident A Transport Assessment and Travel Plan Person’s Homes and bed spaces are required to support the level of parking. Nursing Homes (Source: London Plan) EDUCATION AND HEALTH C2 Hospitals Considered on an 1 space per 5 staff Full details of staff numbers, bed spaces individual basis using a plus 1 space per 10 and visitors will be required to support the transport assessment and staff for visitors level of parking. travel plan to support the (Source: UDP) level of parking.

LDF – Development Policies and Site Allocations, Preferred Options Report 44 Use Class Description Parking Standard Cycle Parking Detail (Maximum) (Source: London Plan)

D1 Adult training centres, Considered on an 1 space per 10 staff Non-residential conference centres, individual basis using a plus 1 space per 10 institutions libraries and community transport assessment visitors centres (Source: London Plan) (Source: UDP) Higher and further Considered on an 1 space per 8 education establishments individual basis using a staff/students (vocational and academic) transport assessment and (Source: UDP) travel plan to support the level of parking. (Source: London Plan) Day centres and pre- 1 space per 2 staff school play and nursery (Source: London Plan) provision Primary, secondary and Considered on an Primary and special Non-residential education and training special schools individual basis using a school: centres may require some parking for staff transport assessment and 1 space per 10 staff and operational requirements but the focus travel plan to support the Secondary school of attention should be on child safety, level of parking. 1 space per 10 including segregation of vehicle and students/staff pedestrian movements on site. Safer (Source: UDP) routes to School programmes should be promoted. Safe and convenient dropping off/collection areas should be provided for parents’ cars and coaches/school buses. Medical and other health Considered on an 1 space per 5 staff A Transport Assessment and Travel Plan practices, including dental, individual basis using a (Source: UDP) may be required to support the level of veterinary and alternative transport assessment. parking. medicine LEISURE D1 Places of worship Considered on their merits

D2 Theatres and cinemas Considered on an 1 space per 50 seats A Transport Assessment and Travel Plan individual basis using a (Source: UDP) may be required to support the level of

LDF – Development Policies and Site Allocations, Preferred Options Report 45 Use Class Description Parking Standard Cycle Parking Detail (Maximum) transport assessment. parking.

Health clubs, licensed Considered on an 1 space per 10 staff A Transport Assessment and Travel Plan clubs and sports facilities individual basis using a plus 1 space per 20 may be required to support the level of with or without a licensed transport assessment. peak period visitors parking. clubhouse (Source: UDP) DISABLED All Use Classes 10% of all parking Parking for disabled people is additional to provided at a minimum of the maximum parking standards. 2 parking bays. The appropriate number of disabled parking bays will be assessed on the size of the site and the nature of the proposed use. (Source: London Plan) MOTORCYCLE, MOPED AND SCOOTER PARKING All use classes The parking spaces should be located as near as possible to the building entrance(s). Large developments will be expected to include shower and changing facilities.

Use Classes Use Classes are defined by the Town and County Planning (Use Classes) Order 2000.

Floor space The floor space in all cases refers to gross floor area, including the thickness of walls, unless otherwise indicated. RFA refers to retail floor area.

Standards (a) All standards are maximum unless otherwise stated.

LDF – Development Policies and Site Allocations, Preferred Options Report 46 (b) The parking requirements are calculated separately for each use where several land uses are combined within one scheme. However, where mixed uses clearly generate demands at different times of day, consideration will be given to a level of parking provision based on the maximum amount of parking space required at any one time. (c) All calculations should be rounded up to the nearest whole number. (d) All staffing figures should be read as full-time equivalent staff employed at peak times.

Parking space sizes The minimum dimensions are: Standard car parking space (or bay): 2.4m x 4.8m Wheelchair accessible car parking space: 3.6m x 4.8m Motorcycle/ moped/ scooter parking space: 1.4m x 2.5m Articulated vehicle space: 3.5m x 18.5m Coach space (60 seats): 3.5m x 14.0m

Note: • The term ‘one space’ used in the standards refers to standing area only and does not include manoeuvring space or space for un/loading. • Single garages will be accepted as parking space for bicycles if the internal width exceeds 3.5m or the length 5.3m.

Loading Arrangements Sufficient space for the standing and manoeuvring of all goods vehicles likely to serve the development at any one time is essential. At least 50m2 should be provided, laid out to accommodate the largest vehicle likely to be accommodated. Development layouts should allow all vehicles to enter and leave the site in a forward direction.

Car parking layouts All surface car parks should be adequately screened and landscaped and where possible laid out in small groups of parking spaces. Development will only be permitted where it provides off-street parking, turning, loading and unloading for service vehicles to the satisfaction of the Local Planning Authority. Attention should be paid to “Secure by Design” considerations.

New Buildings, Extensions and Changes of Use The council will have regard to existing parking on a site and may consider the possibility of a reduction in the amount of parking where the new use requires fewer spaces than the existing use of the site. Where standards differ between uses in the same Use Class or between uses which are

LDF – Development Policies and Site Allocations, Preferred Options Report 47 allowed as permitted development under the Town and Country Planning (General Permitted Development) Order 1995, conditions may be applied to planning permissions restricting rights to change the use of the site without the consent of the LPA.

Development not providing parking Developments below the relevant parking standard threshold will be considered on their merits having regard to the transport and parking strategy and regeneration objectives. The required parking provision will be used as a starting point in negotiating suitable on-site parking. The Council will have regard to the level of public transport access and the proposed uses.

Uses not mentioned For uses not mentioned provision will be a matter for negotiation between the applicant and the Council, considered on their merits based on restraint. For large scale developments a travel plan will normally be required.

Parking for wheelchair users and people with disabilities In accordance with PPG13, there will be a requirement for an additional 10% of all parking spaces on a site to be designated as disabled parking bays. However, the London Plan advises that there should be flexibility with this requirement and therefore the appropriate number of disabled parking bays will be assessed on the size of the site and the nature of the proposed use. The disabled parking bays will be required to be provided to the mobility standard of 3.6m x 4.8m, specifically marked out and positioned as near as possible to the entrance of the building. As a guide at least two parking bays should be for this use.

Multiple use of parking facilities Applicants may consider the multiple use of parking facilities (for use by different sections of the community, for different uses and either at the same or at different times). The multiple use of parking facilities may require planning permission and applicants should contact the Local Planning Authority to discuss their proposals before proceeding. Shared parking or multiple use of parking spaces may be encouraged to maximise parking in appropriate locations. Multiple use parking will only be permitted where there is full co-operation from all occupiers. Such parking arrangements will not be considered as a means of meeting the required parking standards for a development.

Front garden and garage parking Hard surfacing of front gardens to provide new or additional off-street parking can be detrimental to the local streetscape and character. Where new or additional parking is unavoidable, design advice should be sought from the Council. Similarly, the conversion of garages to provide additional accommodation can have a harmful effect, particularly if the alteration is out of keeping with the original dwelling. Again, design guidance should be sought from the Council. This particularly applies in conservation areas. Where a space within a curtilage is a garage, a condition will normally be

LDF – Development Policies and Site Allocations, Preferred Options Report 48 applied, preventing the garage from being used as a habitable room to ensure it remains as a parking space. Garages will be required to maintain an internal width of 3000mm.

Uses likely to generate coach traffic Uses likely to generate coach traffic (e.g. hotels, public halls, educational establishments, swimming and sports facilities, theatres etc) should provide adequate off-street facilities for coaches, including pick-up and set-down points, manoeuvring space and sufficient parking bay(s). Development layouts should allow for coaches to enter and leave the site in a forward gear.

Cycle parking Cycle parking facilities should be conveniently located, secure, easy to use, sheltered, well lit and signposted. Details will need to be submitted with a planning application.

LDF – Development Policies and Site Allocations, Preferred Options Report 49 3.2.4 PROMOTION OF PUBLIC TRANSPORT IMPROVEMENTS In general the Council will support and promote public transport improvements that are of benefit to local residents. There is also a need to protect essential transport infrastructure without which the transport system would not function. The Council also promotes and supports new public transport provision and improvements of existing facilities. Although the provision of new rail and bus routes are the responsibility of other public and private bodies such as central government, the Mayor of London and the various rail and track operators, the Council believes it is important to state publicly that it supports certain proposals.

The Options Three options were put forward as part of the Issues and Options consultation. 1. The Council will encourage the safeguarding of transport facilities through avoiding inappropriate development. 2. The Council will support and promote public transport improvements. 3. The Council will support rail and other transit improvement schemes that benefit local residents, subject to acceptable environmental impacts, in particular: • East London Railway • Extension of DLR from Lewisham to Catford • DLR 3 car capacity enhancement • Extension of the Croydon Tramlink to Lewisham • Extension of the Greenwich Waterfront Transit to Canada Water • Orbital rail route improvements

The Preferred Option The preferred options is to proceed with options 1 and 2 as they relate to transport interchanges as the other options are being pursued through the Spatial (Core) Strategy Development Plan Document.

Draft Policy

T17 Transport interchanges (a) Better interchange within public transport, and between public transport and private transport, will be sought as opportunities arise. Where appropriate developments should improve such facilities and provide for cycle access. (b) A comprehensive programme of interchange improvements will be pursued with relevant agencies and transport providers. (c) The use of planning obligations and conditions on planning permissions may be used in pursuit of this policy.

Reasons for the Preferred Option Consistency with national and regional planning guidance The London plan sets out the major transport schemes and developments that the Mayor supports. Some of the proposals supported by the Council are not included in the current 10 year plan for transport improvements. However, the council considers early promotion of transport improvements to be worthwhile while acknowledging that the money and authority to implement these schemes does not lie with the Council. London Plan policies which supported the preferred options include policy 3C.9 (Increasing the capacity, quality and

LDF – Development Policies and Site Allocations, Preferred Options Report 50 integration of public transport to meet London’s needs), 3C.10 (Phasing of transport infrastructure), 3C.11 (New cross-London links with an improved National Rail network), 3C.12 (Improved underground and DLR services) , 3C.13 (Enhanced bus priority, tram and bus transit schemes) and 3C.19 (Improving conditions for buses).

The preferred options support TfLs Business Plan 2005/9 -2009/10, 5 Year Investment Strategy.

The preferred options support the implementation of the London Bus Priority Network, accessibility improvements at bus stops, promoting new bus service links such as between Blackheath and Greenwich and public transport improvements to new developments.

Consistency with other Council documents The Lewisham Local Implementation Plan is a statutory plan to implement the London Mayor’s Transport Strategy. The actions set out in the draft LIP are supportive in the promotion of public transport and seek improvements in the Borough.

What alternatives were considered and why were they rejected It was not considered appropriate to consider options as the transport improvement proposals put forward are the responsibility of other organisations and the Council is only required to reflect the appropriate land use policies in the emerging LDF.

Other planning reasons Integrated transport opportunities promotes passenger convenience and use. Through its development control functions the Council can attempt to ease its problems of physical interchange. Public transport operators will be urged to improve the accessibility of their vehicles and rolling stock for the use of people with disabilities and to provide new or improved services.

LDF – Development Policies and Site Allocations, Preferred Options Report 51 The Road Hierarchy (taken from the UDP and LIP)

Strategic Routes (Transport for London Road Network) A2 New Cross Road to Shooters Hill Road (including Kender Street) A20 New Cross Road to Eltham Road A202 Queens Road to New Cross Road A21 Molesworth Street to Bromley Hill A205 South Circular

London Distributor Routes (LBL Responsibility) A212 Westwood Hill to Catford Hill A213 Newlands Park A200 Evelyn Street to Creek Road A2015 Beckenham Hill Road A2209 Deptford Church Street A2210 Brookmill Road, to Baring Road A2211 Lewisham Road A2212 Burnt Ash Road, Baring Road A2214 Lausanne Road A2216 Dartmouth Road to Sydenham Road A2218 Southend Lane and Stanton Way

Local Distributor Routes B206 Plough Way to Grove Street B207 Trundleys Road Pagnell Street B220 Belmont Hill to Prince of Wales Road B212 Lee Road B218 Florence Road to Brockley Rise B226 Chinbrook Road to Grove Park Road B227 Perry Vale to Perry Rise B236 Adelaide Avenue to Ladywell Road B238 Forest Hill Road to Honor Oak Park B2142 Gellatly Road to Brockley Cross Hither Green Lane

Local Access Roads All other roads not identified in the above list.

LDF – Development Policies and Site Allocations, Preferred Options Report 52 3.3 RETAIL AND TOWN CENTRES

Overview The London Borough of Lewisham recognises that it has a key role to play in encouraging retailing and town centre development, as well as having regulatory planning control. As such, the Council must provide an adequate framework within the Spatial (Core) Strategy and Development Plan Documents to enable the retailing industry to establish and maintain appropriate town centre facilities in a way that meets the objectives of the Government’s sustainable development agenda.

This chapter deals with: • District centres • Neighbourhood centres and • Local Shopping Centres and Parades and • Out of Town centres

And discusses their: • Role and function • Vitality and viability • Accessibility and car parking • High quality environment and design • Modification to any of the boundaries

LEWISHAM AND CATFORD MAJOR TOWN CENTRES The preferred options for the Lewisham and Catford town centres are included as part of the Spatial Strategy and are the subject of separate area action plans which provide the planning and policy framework for their regeneration and on-going development.

DISTRICT CENTRES The role and function of the district centres changes from centre to centre. However, there is need to consider this role and function and determine whether it should be maintained, improved or encouraged in a particular direction. Each district centre have unique characteristics much of which is linked to the surrounding communities. Some centres have strong evening economies, others provide a vibrant local convenience market and others a balance of comparison and convenience stores. These attributes provide a variety of centres within the London Borough of Lewisham. These District Centres comprise of: • Blackheath • Deptford • Downham • Forest Hill • Lee Green • New Cross and New Cross Gate • Sydenham

LDF – Development Policies and Site Allocations, Preferred Options Report 53 Issues and Options Consultation The main responses from the Issues and Options DPD consultation were: • With the dominance of car-orientated supermarket provision, it is difficult to see how every small shop can survive. With good design standards, continuing the conversion of derelict retail premises to residential use greatly improves the appearance of an area. • Support the move from retail to alternative uses in Local Shopping centres and Parades. • Out of centre retailing has destroyed vitality & viability of local high streets and should be firmly discouraged. • Large scale bulky goods retailing should be encouraged in town centres or at edge of centre only. • Car parking is a problem. • Cycling and walking should be encouraged by new development. • New Cross does not function well as a 'District Centre' currently. Needs to primarily cater for the local student population/enhance/evening economy. • Overlay 'special districts' at Deptford station/Resolution Way. • Restriction on uses in Blackheath is important to maintain some balance & provide some basic convenience shopping. • An evening economy is needed in Lewisham Town Centre. • A Metropolitan status would be benefit to the wider area of Lewisham Town Centre and would capitalise on the improved public transport links now available.

Relationship to the Community Strategy The Community Strategy deals with the economic, social and environmental well-being of the Borough and seeks to improve the quality of life in Lewisham. It has been prepared by the Lewisham Strategic Partnership in consultation with the London Borough of Lewisham. As such it deals with a range of public service issues well beyond the remit of the Local Development Framework. Nevertheless, consultation with local people on the Strategy has revealed a high level of concern about issues that are central to the LDF. The main areas in which Retail and Town Centres aim to deliver the Community Strategy is through fostering enterprise and sustainable business growth including the creative industries, by securing the sustainable regeneration of Lewisham and through to improving the effectiveness, efficiency and sustainability of local public services. This reinforces the Community Strategy’s Action Plans 4, 6 and 10.

3.3.1 ROLE AND FUNCTION The Borough’s district centres have many convenience shops catering for the diverse local multi-cultural community and there primary role and function is that of a local convenience supplier of goods and services. This is illustrated by the small number of comparison goods outlets and the high proportion of service uses located within Deptford, Downham, Forest Hill, Lee Green and Sydenham. The limited number of ‘high street’ names are located in low quality properties and the dominance of the busy roads through the district centres creates a difficult pedestrian environment.

Deptford is set to be transformed through the £25 million investment in a replacement Deptford railway station which will provide a safer, accessible and more welcoming environment. The project will also provide much needed housing as well as safeguard and enhance the historic carriage ramp, one of the oldest surviving railway structures in London. It is proposed that a Design led strategy to improve the function of the open spaces and routes into and out of Deptford is combined with other regeneration opportunities in the area. Therefore, a North Lewisham Masterplan has been produced which seeks to reinforce the role of open spaces and connectivity between regeneration sites and key transport links.

LDF – Development Policies and Site Allocations, Preferred Options Report 54

Downham is the smallest district centre with its location being sited between Catford and Bromley also indicate that the general nature of the shopping area is service and convenience orientated.

The recent high vacancy levels in Forest Hill are considered to be influenced by the properties involved in the Sainsbury’s expansion and as such could potentially have a detrimental effect to the rest of the centre.

There are 82 units contained within the Lee Green centre, 62 within Lewisham and 20 within Greenwich The majority of floor space are in convenience stores, the largest being Sainsbury’s. In addition there are a range of service uses and a reasonable amount of office space within the town centre.

The New Cross centre is located in the north of the Borough and is the fifth largest centre. The centre does not contain a core retail area with the main shopping function being on the northern side of New Cross Road which is designated within the UDP as non-core retail. The high level of service uses is also influenced by the presence of the student population from Goldsmiths College. The Sainsbury’s store at the western end of the centre is likely to have a wide retail catchment.

The Sydenham district centre provides for the day to day needs of the local population. The higher than average convenience floor space and the lower than average comparison offered indicate this local function.

The Options A choice of six options were put forward as part of the options for District centres in the issues and options consultation.

1. Maintain and enhance the existing focus and strength of the role and function of district centre, of that of a local service centre. 2. Enhance the existing focus and strength of the role and function of the District town centre, to that of a local service centre. 3. Aim to attract more national names to diversify the provision of goods and services within the District centres. 4. Enhance and further encourage the existing strength of the evening economy. 5. Increase the number of comparison stores, towards a balance of convenience and comparison outlets, similar to national averages (i.e. to enhance the day time economy). 6. Encourage new residents to the area, which would require a greater variety of shops to the Deptford district centre.

The Preferred Option The preferred option is to proceed with option 1 and 6

Reasons for the Preferred Option Consistency with National and regional planning guidance

LDF – Development Policies and Site Allocations, Preferred Options Report 55 The preferred option supports the objectives detailed in PPS6 which states that the Government’s key objectives for retail and town centres is to promote their vitality and viability by planning for the growth and development of existing centres. This includes promoting and enhancing existing centres by focussing development in such centres and encouraging a wide range of services in a good environment accessible to all.

The London Plan policies 3D.1 (Supporting town centres) and 3D.3 (Maintaining and improving retail facilities) are also supported by the preferred option.

Community Strategy and other Council policy documents The Council’s Community Strategy and specifically the objectives to foster enterprise and secure sustainable regeneration as set out in Action Plan 4 is supported by the preferred option. Deptford is proposed to undergo a complete facelift with substantial investment in all sectors as outlined in the draft North Lewisham Masterplan and the draft Lewisham Regeneration Strategy. In light of these changes, the option for mixed use development will be acceptable in principle subject to other policies in the LDF.

Issues and Options Sustainability Appraisal Responses strongly supported the preferred option to maintain the current levels of diversity offered within the town centre.

What alternatives were considered and why they were rejected. Option 1 provided more scope for the viability of the district town centres and was more adequately reflective of the direction, the core strategy aims to pursue. As such Option 2 was considered unfavourable.

Option 3 was focused towards vying for inward investment from large high street retailers. To some extent this will be a long term goal for the future of the boroughs district centres but this could place unwanted pressure on existing convenience stores and retailers.

Option 4 was an important issue but wasn’t the main impetus for the role and function of Lewisham’s District Centres.

Option 5 is relevant and necessary to fortify the role of District centres and to be able to compete against some of the larger retail areas within and outside the borough. However, as indicated in the Boundary issues, it was decided that no expansion would be made within this plan period. As such this option was unfavourable.

3.3.2 VITALITY AND VIABILITY Ensuring town centre vitality and viability is a key objective for the Council and is in keeping with the national policy direction of PPS6. Vitality and viability can primarily be achieved through planning for the growth of existing retail and town centre areas and promoting and enhancing existing centres. There are currently no core or non-core areas designated within the New Cross district centre.

The Options

LDF – Development Policies and Site Allocations, Preferred Options Report 56 Three options were put forward as part of the options for District centres in the issues and options consultation.

1. The use of designated Core and Secondary or Non-Core areas within the District Centre. 2. Specialist areas or quarters which have a focus on a particular/complimentary use/activity. 3. No restrictions on various uses within the designated centre boundary.

The Preferred Option The preferred option is to proceed with a combination of options 1, and 2 in the boroughs district centres. This would see the use of Core and Non-Core shopping areas within the District Centre, which would be extended further than the existing core area as well as a focused ‘specialist area’ surrounding the Deptford train station development. This ‘specialist area’ surrounding the train station will allow flexibility for considering applications which will enable a more diverse evening economy to establish in the area surrounding the train station in line with the North Lewisham Masterplan currently being prepared.

Reasons for the Preferred Option Consistency with national and regional planning guidance The preferred option supports the objectives detailed in PPS6 which states that the Government’s key objectives for retail and town centres is to promote their vitality and viability by planning for the growth and development of existing centres. This includes promoting and enhancing existing centres by focussing development in such centres and encouraging a wide range of services in a good environment accessible to all.

The London Plan policies 3D.1, supporting town centres specifically mentions designating core areas primarily for shopping uses and secondary areas for shopping and other uses and setting out policies for the appropriate management of both types of area. Policy 3D.3 of the London Plan, maintaining and improving retail facilities, is also supported by the preferred option.

Community Strategy and other Council policy documents The Council’s Community Strategy, and specifically the objectives to foster enterprise and secure sustainable regeneration as set out in Action Plan 4 is supported by the preferred option.

The Lewisham Town Centre Health Checks 2004 report illustrates that currently all District Town Centres Downham, Forest Hill, Lee Green, New Cross and Sydenham have not been successful in maintaining 70% A1 use within the core area so any core area policy would need to be considered against the existing unsuccessful one. Therefore there is an identified need to protect these uses, and this can most effectively be done through the use of a core and non-core area policies.

LDF – Development Policies and Site Allocations, Preferred Options Report 57 Table 2. Town Centre Health Checks - 2004

BLACKHEATH DEPTFORD DOWNHAM CENTRE TYPE District District District PTAL 3 3 2 TOTAL FLOORSPACE 11,519 28,242 n/a (sq.m) TOTAL UNITS 123 259 73 A1 UNITS TOTAL (%) 73 (59%) 155 (60%) 45 (62%) A2 UNITS TOTAL (%) 17 (15%) 18 (7%) 5 (7%) A3 UNITS TOTAL (%) 28 (23%) 35 (14%) 13 (18%) OTHER UNITS TOTAL (%) 4 (3%) 25 (10%) 7 (10%) VACANT TOTAL (%) 1 (1%) 26 (10%) 3 (4%)

FOREST LEE NEW SYDENHAM HILL GREEN CROSS CENTRE TYPE District District District District PTAL 3 3 6 3 TOTAL FLOORSPACE 18,209 n/a 20,930 23,876 (sq.m) TOTAL UNITS 156 90 109 179 A1 UNITS TOTAL (%) 60 (38%) 41 (46%) 44 (40%) 97 (54%) A2 UNITS TOTAL (%) 15 (10%) 6 (7%) 9 (8%) 19 (11%) A3 UNITS TOTAL (%) 29 (19%) 20 (22%) 29 (27%) 30 (17%) OTHER UNITS TOTAL (%) 12 (8%) 12 (13%) 10 (9%) 19 (11%) VACANT TOTAL (%) 40 (26%) 11 (12%) 17 (16%) 14 (8%)

Issues and Options Sustainability Appraisal: Options 1 and 2 proved the most sustainable within all of the district centres.

What alternatives were considered and why they were rejected. Allowing this form of development would see an undistributed rise in un-neighbourly uses and a potential loss of essential uses e.g. A1. Option 3 would be inconsistent with National and Regional policy.

3.3.3 ACCESSIBILITY Accessibility is part of the essential mix to any successful retail and town centre. Whilst the main issues on this matter will be included under the transport chapter it is necessary to consider the impact and location of transport networks and the interchanges within the borough’s district centres.

Blackheath and Forest Hill are well served by mainline rail services and buses. There are also a significant number of on-street parking spaces within and around the centre which facilitate commuters.

Deptford, New Cross and Sydenham are all located on the rail network, which provide good access to the centre. Improvements to the Deptford train station and surrounds are anticipated to commence in the near future. with the railway stations at New Cross, New Cross Gate and Sydenham offering frequent services to central London, Lewisham, other areas within the Borough, the South East, and also interconnect with the London Underground East London line.

LDF – Development Policies and Site Allocations, Preferred Options Report 58 Lee Green, New Cross and Sydenham provide good car parking facilities and bus services connecting these centres with Lewisham, Catford and the surrounding area. Within the three centres there are at least eight bus services which serve the centre as well as 19 departing from either New Cross station or New Cross Gate railway stations and at least nine bus services departing from Sydenham into Central London. With the exception of Sydenham, many of the car park facilities are provided for by large retailers with some car parks accommodating up to 400 vehicles.

The Option One option was put forward as part of the issues and options consultation. 1. Encourage greater accessibility by public transport, walking and cycling to all retail and town centres.

The Preferred Option The one and only option put forward is the preferred option. Which would also be in accordance with policy CP30 of the Core Strategy.

Reasons for the Preferred Option Consistency with national and regional planning guidance The preferred option supports the objectives detailed in PPS6, as well as supporting London Plan policies 3D.1 which specifically refers to improving access to town centres by public transport, cycling and walking.

Community Strategy and other Council policy documents The Council’s Community Strategy and specifically the objective to secure sustainable regeneration as set out in Action Plan 6 is supported by the preferred option.

Issues and Options Sustainability Appraisal: There was support for this option from the issues and options consultation exercise and there were no further options which were put forward as part of the consultation.

What alternatives were considered and why they were rejected. There were no alternative options.

3.3.4 HIGH QUALITY ENVIRONMENT AND DESIGN

There is a need to ensure that retail and town centres provide a high quality environment, as well as encouraging good design. The preferred options developed as part of this chapter will link to the preferred options for urban design.

The Options Two options were put forward as part of the issues and options consultation. 1. Policies which encourage good quality design and seek improvements to the existing retail environment. 2. Development of a specific design guide for each of the District Town Centres.

LDF – Development Policies and Site Allocations, Preferred Options Report 59 The Preferred Option The preferred option is to proceed with option 1 and encourage good quality design and seek improvements to the existing retail environment and to set a high standard of design for future retail needs, in accordance with policy CP30 of the Core Strategy. It should be noted that Forest Hill is the only district centre which has had a design guide produced

Reasons for the Preferred Option Consistency with national and regional planning guidance The preferred option supports the objectives in PPS1 and PPS6, as well as supporting London Plan policies 4B.1 (Design Principles for a compact city) and 4B.7 (Respect local context and communities).

Community Strategy and other Council policy documents The Council’s Community Strategy, and specifically the objective to secure sustainable regeneration as set out in Action Plan 6 is supported by the preferred option.

Issues and Options Sustainability Appraisal: Responses supported the preferred option. There was support for both options. One response wanted to undertake a design award for a new Lee Gate Centre.

What alternatives were considered and why they were rejected. Option 2 was dismissed as design advice is considered to be adequately covered in other development control policies and design guidance for shopfronts and centres which fall in Conservation areas are also covered in supplementary planning guidance. It should be noted that there are limited development sites within the Downham area and therefore the preparation of a design guide for the area would have limited implementation.

3.3.5 BOUNDARY ALIGNMENT Should the existing boundary for the District Centres in Lewisham be modified?

The Options Two options were put forward as part of the issues and options consultation. 1. Retain the boundaries as currently indicated in the UDP. 2. Modify the district centre boundary with alternative configurations.

The Preferred Option (Downham, Lee Green, and Sydenham) The preferred option is to proceed with option 1 for the District centres of, Downham, Lee Green and Sydenham and to proceed with option 2 for the District Centres of Blackheath Deptford, Forest Hill and New Cross. . Reasons for the Preferred Option Consistency with national and regional planning guidance Both options support PPS6 which states that local planning authorities should define the extent of the town centre on the proposals map (Para 2.16) which the preferred option will achieve. The town centre boundary specifically supports London Plan policies 3D.1, 3D.2 and 3D.3.

LDF – Development Policies and Site Allocations, Preferred Options Report 60

Community Strategy and other Council documents The Council’s Community Strategy, and specifically the principles to foster enterprise and sustainable business growth, and secure sustainable regeneration (housing, transport and environment) as set out in Action Plans 4 and 6 which support the preferred option.

In light of the recent Local Centres Survey undertaken since the Issues and Options consultation, it is evident that the New Cross district centre and the New Cross Gate local centre are located within close proximity. This is reflected in the fact that the Council employs one town centre manager to cover both areas. To enhance this area and enable development to be focused on serving local community needs it is considered beneficial to join the centres into a larger district centre.

The consultation raised a suggestion to expand the Deptford town centre boundary to the north to include both sides of the High Street.

Issues and Options Sustainability Appraisal There was support for both options.

What alternatives were considered and why they were rejected. No alternative alignments were proposed for the District Centre boundaries of Blackheath, Downham, Forest Hill, Lee Green, and Sydenham.

The Preferred Option (Blackheath) The preferred option is to proceed with option 2 and modify the boundaries of the Blackheath centre to incorporate all of the land owned and occupied by Network Rail (4). Another site to the north east boundary seeks inclusion into the town centre boundary as the proposed area serves a town centre function (3). As well as this site a representation calls for the removal of two residential sites within the town centre boundary which do not contribute to the role and function of a town centre (1 & 2). See Figure 1.

LDF – Development Policies and Site Allocations, Preferred Options Report 61 Figure 1. Proposed additions and deletions to Blackheath

Issues and Options Sustainability Appraisal There was support for an option to modify the boundary by excluding the residential area to the east and west of the site.

What alternatives were considered and why they were rejected. Consideration has been given to modifying the alignment of the district centre boundary, however, for implementation purposes it is considered most appropriate that the boundary follow road layout and therefore has been retained as is existing, rather than excluding the residential portion on the fringe of the centre.

The Preferred Option (Deptford) The preferred option is to proceed with option 2 to modify the boundary of the Deptford Town Centre boundary to include a cultural area, and an additional parcel of land to the north of the boundary to fortify and improve the quantum of retail within the town centre (1) as detailed in Figure 2.

LDF – Development Policies and Site Allocations, Preferred Options Report 62

Figure 2. Proposed additions and deletions to Deptford

Issues and Options Sustainability Appraisal: The issues and options report details option 1 and 2 as equally sustainable which both benefit the vitality and viability of Deptford.

What alternatives were considered and why they were rejected. Option 1 was dismissed as the proposed boundary provides a more coherent town centre.

The Preferred Option (Forest Hill) The preferred option is to proceed with option 2 and modify the boundary of Forest Hill district centre as the residential area to the north west is wholly residential and

LDF – Development Policies and Site Allocations, Preferred Options Report 63 representations suggest that this site (1) does not contribute to the role and function of the Forest Hill town centre. See Figure 3.

Figure 3. Proposed additions and deletions to Forest Hill

Issues and Options Sustainability Appraisal The issues and options report details option 1 and 2 as equally sustainable which both benefit the vitality and viability of Deptford.

What alternatives were considered and why they were rejected. Consideration has been given to retaining the existing alignment of the district centre boundary, however, this residential element of the town centre does not fulfil the role and function of a town centre and should be taken out so that future policy can be more effective.

The Preferred Option (New Cross) The preferred option is to proceed with option 2 and modify the boundaries of the New Cross centre to incorporate a site between New Cross Gate station and 267 New Cross Road and 17 – 25 Goodwood Road to allow a mix of retail, B1 offices, residential and community facility (1), part of the hostel site was found within the town centre boundary and attributed it to

LDF – Development Policies and Site Allocations, Preferred Options Report 64 some confusion, as such the new boundary encompasses the hostel and a row of houses which front Pagnell Street (2). The New Cross Gate Local shopping centre has been thriving as a local centre and competes very well with the existing New Cross District Centre. In light of its success, a suggestion about combining the two centres was put forward (3). See Figure 4.

LDF – Development Policies and Site Allocations, Preferred Options Report 65

Figure 4. Proposed additions and deletions to New Cross

LDF – Development Policies and Site Allocations, Preferred Options Report 66 Issues and Options Sustainability Appraisal There was support for an option to modify the boundary by excluding the residential area to the north.

What alternatives were considered and why they were rejected. Consideration has been given to modifying the alignment of the district centre boundary, however, for implementation purposes it is considered most appropriate that the boundary follow road layout and therefore has been retained as is existing, rather than excluding the residential portion on the fringe of the centre.

Draft Policies

RTC 1 Principles for Retail development and other Town Centre Use (Excludes Lewisham and Catford Town Centres)

Proposals for retail development and other key town centre uses will be determined on:

1. An assessment of need for the development in the format proposed.

2. Identification of the appropriate scale of the development in relation to the retail hierarchy set out in CP 30.

3. Application of the sequential test to site selection.

4. Assessment of the impact of the development on existing centres in Lewisham, the East London sub region and neighbouring centres, including the cumulative impact of recent and committed development sites in the locality. This applies to proposals which would have a gross floorspace in excess of 2500 square metres.

5. The effect on amenities of adjoining property and/or residential occupiers.

6. That the location is easily accessible and well served by a choice of means of transport.

Edge of centre retail, leisure, office, employment and community schemes will need to demonstrate that they can effectively integrate with existing frontages.

Planning obligations may be sought in pursuant to this policy.

LDF – Development Policies and Site Allocations, Preferred Options Report 67 RTC 2 Types of uses in Core, Non- Core and Other shopping Areas (Excludes Lewisham and Catford Town Centres)

The following uses are considered acceptable in principle at ground floor level:

Core: Class A1 shops, A2 Banks and Building Societies, A3 Restaurants

In Non- Core Shopping Areas, in addition to the uses defined for Core, the following uses are also considered acceptable in principle at ground floor level:

Non Core: A4 Public Houses (Pubs) and Bars Class A5 Hot food Takeaway Community Services, including GP surgeries, Veterinary Surgeries, Dentists and other similar uses. Launderettes and Amusement centres

Other: Notwithstanding the uses acceptable in Core and Non Core shopping Areas, applications for development or change of use which involves the loss of A1 units will normally be acceptable provided:

1. It does not harm the amenity of adjoining properties 2. It does not harm the local distinctiveness, vitality and viability of the centre as a whole. 3. That in the case of a change of use to residential use that the frontage for shoppers is not unreasonably interrupted.

Changes of use from Class A1 (Retail) will be acceptable within designated shopping areas where A1 usage is greater than 70% in the Core and 50% in Non- Core and does not separate retail units by more than 12metres or 3 A1 uses together (whichever is the greater), unless an applicant can demonstrate that the proposal would enhance the character, vitality and viability of the centre and would not adversely affect the retail function as set out in CP 30 of the Core Strategy.

Proposals for the change of use into A3, A4 or A5 will be assessed in conjunction with RTC 5.

The proposal should improve the shopping range, quality and function of the Shopping Area and the retail centre as a whole.

Proposals amounting to more than 1000 square metres gross floorspace within the town centre boundaries must be accompanied by a Green Travel Plan.

LDF – Development Policies and Site Allocations, Preferred Options Report 68 3.3.6 LOCAL SHOPPING CENTRES AND PARADES There are many local shopping centres and parades within the Borough which are defined as Neighbourhood Centres, Local Centres, Local Parades and Corner shops within the retail hierarchy (See CP 30) a group of at least four continuous shops. The size, range, function and character vary between each centre.

Role And Function The main function of the local shopping centre or parade is to provide for the day to day needs of local residents (small scale convenience goods) within easy walking distance and to supplement the facilities located in larger shopping centres such as that found within the Major and District Centres. It is considered important to maintain local shopping centres and parades to ensure that the less mobile members of the community have access to a range of shops. The council does acknowledge, that in the past it has not always been possible to retain all of the shops in the Borough especially where demand is insufficient to ensure economic viability. In such circumstances consideration has been given to a change of use to residential, providing that this does not adversely impact on the viability and vitality of the surviving retail uses.

The Options Three options which put forwards as part of the issues and options consultation. 1. The role and function of local shopping centres and parades is to provide for the daily needs for goods and services for the surrounding local community. This role should be maintained, enhanced and where possible further encourage this local role and function. 2. Maintain the current level of flexibility for the change of use. 3. Plan for the decline in unsuccessful centres. Planning policies could address decline in some centres. This information would be formulated for each individual centre and based on local circumstances.

The Preferred Option The preferred option is to proceed with option 1.

Reasons for the Preferred Option Consistency with national and regional planning guidance The preferred option supports the objectives of PPS6 to promote and enhance existing centres, by focussing development in such centres and encouraging a wide range of services in a good environment which is accessible to all, as well as supporting London Plan policies 3D.1, 3D.2 and 3D.3.

Community Strategy and other Council policy documents The Council’s Community Strategy and specifically the objectives to foster enterprise and secure sustainable regeneration is supported by the preferred option.

The Council has undertaken a health check survey of the Neighbourhood centres and will continue to monitor the health of these centres.

Issues and Options Sustainability Appraisal: Responses favoured both options 1 and 3.

LDF – Development Policies and Site Allocations, Preferred Options Report 69 What alternatives were considered and why they were rejected. Options 2 and 3 were dismissed as they are not in keeping with the National and regional guidance and the focus on maintaining and enhancing the role and function of these centres.

Vitality And Viability Ensuring town centre vitality and viability is a key objective for the Council and is in keeping with the national policy direction of PPS6. Vitality and viability can primarily be achieved through planning for the growth of existing retail and town centre areas and promoting and enhancing existing centres. There are various elements which can have an effect on the vitality and viability of neighbourhood centres and this includes accessibility to the centre, ensuring people are able to quickly and easily achieve their needs within the centre, as well as a pleasant shopping environment.

The Options Five options were put forward as part of the issues and options consultation. 1. Encouraging a safe, clean and inviting shopping environment. 2. Seeking to maintain a healthy supply of local shops providing the necessary daily goods and services or plan to contract the shopping function in declining centres. 3. As is current practice, in cases where a shop within a local parade is no longer viable should alternative uses be considered to provide/ensure interaction with the street? 4. A combination of the above options which can be used to maintain, enhance or otherwise, the vitality and viability of the neighbourhood centres. 5. A combination of the above options which can be used to maintain, enhance or otherwise, the vitality and viability of the neighbourhood centres.

The Preferred Option The preferred option is to proceed with option 2.

Reasons for the Preferred Option Consistency with national and regional planning guidance The preferred option supports the objectives detailed in the National Guidance PPS6 to promote and enhance existing centres, by focussing development in such centres and encouraging a wide range of services in a good environment which is accessible to all. In addition the preferred option is supported by London Plan policies 3D.1, 3D.2 and 3D.3.

Community Strategy and other Council Documents The Council’s Community Strategy and specifically the objectives to foster enterprise and secure sustainable regeneration as set out in Action Plans 4 and 6 is supported by the preferred option.

Issues and Options Sustainability Appraisal: There was support for options 2 and 4. A comment was made that the change from retail to residential uses was not supported.

What alternatives were considered and why they were rejected. The preferred option is a combination of elements of the alternative options.

LDF – Development Policies and Site Allocations, Preferred Options Report 70 Draft Policy

RTC3 Local Shopping Centres and Parades

The Council will maintain and enhance the Local Shopping Centres and Parades existing strengths in providing convenience goods and services for a balanced, sustainable and liveable community. New development will need to ensure good design and accessibility.

The Council will grant planning permission involving the change of use from Class A1 in a Local Shopping Parade or as a corner shop, provided the new use would contribute towards preserving or enhancing the local character, vitality and viability of the parade.

In the case of a change of use the following factors will be taken into consideration: (a) the availability of alternative shopping facilities within a comfortable walking distance (approximately 400 metres) (b) the number and type of units within the parade, the vacancy rate and the length of time a unit has been vacant (c) any harm to the amenity of adjoining properties (d) the proposed use maintains an active street frontage to contribute to the vitality and viability of the parade and (e) the design of the proposal is in keeping with the surrounding street frontage and makes a positive contribution to the streetscape. (f) that Class A5 (Hot food Takeaway) uses do not cumulate to a level which would harm the viability and vitality of the Local Shopping Centre or Parade.

Planning obligations may be sought in pursuit of this policy.

3.3.7 OUT-OF-CENTRE PROPOSALS Within the Borough the retail parks at Bell Green and Bromley Road are classified as out-of- centre retail parks. Retail parks comprise a collection of three or more outlets, usually large stores specialising in the sale of household goods (such as carpets, furniture and electrical goods), DIY items and other ranges of goods catering mainly for car-borne customers.

Purpose built retail park premises provide a range of goods not always available in town centres. However, the location of such outlets outside the town centre should be seen as a last resort. Out-of-centre proposals can have an impact on the efficiency and effectiveness of town centre. Existing town centres are generally established shopping areas and are usually well served by public transport. Therefore the out-of-centre proposal should compliment and not compete with retail uses located within the town centres.

The Options Two options were put forward as part of the issues and options consultation. 1 The Sequential Test can be used to guide the location of any out-of-centre development. 2. Current Planning Policy sets guidance for developments, based on the above sequential test, which are greater than 1000sq m of gross floor space. Is this threshold appropriate?

LDF – Development Policies and Site Allocations, Preferred Options Report 71 The Preferred Option The preferred option is to proceed with option 1.

Reasons for the Preferred Option Consistency with national and regional planning guidance The preferred option is in accordance with PPS6 and supports the London Plan policy 3D.2, which seeks town centre development or edge of centre development as a priority rather than out-of-centre proposals.

Community Strategy and other Council documents The Council’s Community Strategy and specifically the objectives to foster enterprise and secure sustainable regeneration as set out in Action Plan 6 is supported by the preferred option.

Issues and Options Sustainability Appraisal: There was support for the preferred option from the consultation undertaken.

What alternatives were considered and why they were rejected. The alternative option is incorporated within the preferred option.

Draft Policy

RTC4 Out-of-centre proposals The Council will grant planning permission for additional retail use, and in particular substantial additional retail development, in the major and district town centres as defined on the Proposals Map. If no suitable, viable or available sites are present in these locations then edge of centre sites should be considered, followed only then by out of centre sites in locations that are or can be made accessible by a choice of means of transport.

Proposals for substantial retail provision on the edge or outside of these Centres will only be considered if the following criteria are satisfied: (a) there is a quantitative and qualitative need for the proposal (b) there are no other sites available in accordance with the sequential test (c) the proposal, either by itself or together with other recent or committed developments would not demonstrably harm the vitality and viability of an existing shopping centre (d) the proposal is sited so as to reduce the number and length of car journeys and can serve not only car journeys but also those on foot, bicycle or using public transport (e) the proposal is not on land allocated for employment purposes on the Proposals Map and for which a demand can be established and (f) if planning permissions were to be granted then a s106 may be negotiated for relevant improvements.

Developments of 1000m2 gross floor space or more will normally be considered substantial.

Proposals amounting to 1000m2 gross floor space or more will require a Green Travel Plan.

LDF – Development Policies and Site Allocations, Preferred Options Report 72 3.3.8 POLICIES RELATING TO ALL RETAIL AND TOWN CENTRES

RTC5 Cultural Quarters

Class A3 (Restaurants), Class A4 (Pubs and Bars) and other appropriate assembly and leisure uses (Class D2) will be deemed acceptable in the following Core, Non Core and Other Shopping Areas where they will not be subject to separation or percentage constraints in order to encourage the formation of cultural quarters. These areas include:

1. Site 15 of the Site Allocations Document (Octavius Street and Deptford Station, Deptford High Street) 2. Site 13 of the Site Allocations Document (Giffin Street, Deptford High Street)

Proposals will be looked at favourably as long as the preferred use does not harm the residential amenity of neighbours and that every precaution is taken in order to avoid disturbance by noise, obtrusive fumes and smells, traffic generation and litter.

RTC6 Evening and Night Time Economy

Within the District centres but outside the Core shopping areas, proposals for recreational and leisure facilities including facilities for arts culture and entertainment pubs, bars, nightclub, bingo halls and any other evening associated use will be acceptable in principle in non core and other shopping areas subject to the following considerations

1. Proximity to Residential areas, Schools, Places of Worship and similar sensitive users. 2. The appropriateness of the scale of the development for the location. 3. The cumulative impact and level of disturbance 4. The nature of the activity, including the impact of the proposed hours of operation 5. The appropriate provision of ventilation and external ducting.

RTC7 Mixed Use Development

The Council will favourably consider new development in the town centre to provide a mix of uses, including independent residential accommodation with separate access. Exceptions may be considered where it can be demonstrated that the site is not suitable to accommodate a mix of uses.

Planning obligations may be sought in pursuant to this policy.

LDF – Development Policies and Site Allocations, Preferred Options Report 73

RTC8 Sui Generis Use

Sui Generis uses and other uses not mentioned in policies RTC 1- 7 will be acceptable in principle in non core and other shopping areas subject to the following considerations

• Proximity to and impact on Residential areas, Schools, Places of Worship and similar sensitive users. • The appropriateness of the scale of the development for the location. • The cumulative impact and level of disturbance • The nature of the activity, including the impact of the proposed hours of operation • The appropriate provision of ventilation and external ducting.

RTC9 Change of Use of Public Houses The Council will only permit the change of use of public houses to other uses where it has been demonstrated that there are alternative remaining public houses in the vicinity and that the potential for alternative community use of the building has been exhausted.

LDF – Development Policies and Site Allocations, Preferred Options Report 74 3.4 OPEN SPACE AND BIODIVERSITY

Overview Open space and Biodiversity is important for both community well being and environmental health. Many people regard the provision and quality of open space in their area as an integral part of what constitutes the quality of life. Open space can play an important role in attracting and retaining residents as well as businesses, and therefore plays an active role in contributing towards socio-economic regeneration and sustainable neighbourhoods. Well designed and managed open spaces can help bring communities together and provides a place to meet and recreate.

As the basis for the development of the adopted Open Space Strategy for Lewisham 2005- 2010, the Council undertook an audit of existing open spaces over 0.3ha including quantity, quality, use, function, facilities and accessibility. Should you wish to view the Open Space Strategy for Lewisham 2005-2010 it is on the Council’s website.

Issues and Options Consultation The main responses from the Issues and Options consultation were:

• Open space should be protected and not encroached on by development and recognised their importance as pockets of open space in a built environment. • The focus group sessions provided an opportunity to probe more closely into how open space impacted on resident’s quality of life. Members commented upon the importance of clean air, a clean environment, and the fact that they are a free facility and the visual importance of open spaces. Even those group members who did not use parks and open spaces acknowledged their value and recognised that they have a positive impact upon the quality of life of local communities.

Relationship to the Community Strategy The Community Strategy deals with the economic, social and environmental well-being of the Borough and seeks to improve the quality of life in Lewisham. It has been prepared by the Lewisham Strategic Partnership in consultation with the London Borough of Lewisham. As such it deals with a range of public service issues well beyond the remit of the Local Development Framework. Nevertheless, consultation with local people on the Strategy has revealed a high level of concern about issues that are central to the LDF. The main areas in which open space and biodiversity supports the borough’s Community Strategy are to protect and enhance the boroughs open space and improve the quality and accessibility of open space to all. This would work towards sustaining the health and wellbeing of local people, develop cultural vitality by building on Lewisham’s distinctive cultures and diversity and also to aid in securing the sustainable regeneration of Lewisham with regard to the environment.

Open Space and Biodiversity Issues

3.4.1 Protection and Enhancement of Open Space and Avoiding Inappropriate Development

The pressure to build new houses in Lewisham will increase over the next 5 years with an estimated 11,178 being needed by 20162 although Brownfield sites should be the preferred land use for development, there is becoming increasingly more strain on open space in the borough. Coupled with this pressure, there has also been a growing level of concern about the state of the health of the borough and in particular the increased levels of obesity

2 Lewisham UDP Revised Deposit Draft

LDF – Development Policies and Site Allocations, Preferred Options Report 75 amongst school age children. The need therefore to provide good quality accessible spaces and facilities for outdoor sport and recreation is vital to help alleviate the problem. Analysis of the function of open space and feedback from local users suggests a need for quality outdoor sports facilities.

It should be noted that human interaction on open space areas can inevitably result in adverse effects on the environmental qualities of the borough’s open spaces. It is therefore important that such activities are managed in such a way that avoids, remedies or mitigates these effects. The same can be said of adjoining properties and development and the potential for spill over effects onto areas of open space.

The Options Eight options were put forward as part of the issues and options consultation. 1. The Council to refuse planning permission for developments within any open space that is likely to result in an adverse effect on its use, management, amenity or enjoyment. 2. The Council to refuse planning permission for developments on land fringing, abutting or otherwise having a visual relationship with any open space that is likely to result in an adverse effect on its use, management or enjoyment. 3. The Council to refuse planning permission for developments on land fringing, abutting or otherwise having a visual relationship with MOL that is likely to result in an adverse effect on its use, management or enjoyment. 4. The Council to protect all MOL and POS from inappropriate built development but adopt a more permissive approach to development on private open space/ Urban Green Space (UGS) based on criteria such as: – Design – Scale – Visual Amenity – Views – Light 5. Requirement that any new development sets aside 1.7ha/1000 head of population average of Open Space. 6. Development contributions to acquire land or cash for future acquisition of land, or for maintenance of nearby open space, relative to the increase in population pressure. 7. Council to negotiate with landowners to open up private open space to allow public access. 8. An assessment of the availability of brownfield land to be designated for open space regeneration.

The Preferred Option The preferred option is to proceed with a combination of options 1,2, 3 and 5.

Draft Policies

OS1 Metropolitan Open Land and land adjacent to Metropolitan Open Land The open character of Metropolitan Open Land (MOL) in Lewisham, as shown on the proposals map, will be preserved. Any development proposal on land fringing, abutting or otherwise having a visual relationship with MOL will be assessed on the basis of their impact on visual amenity, character or use of the MOL. Planning permission will be granted only for appropriate development or change of use where this preserves the open nature of the land.

LDF – Development Policies and Site Allocations, Preferred Options Report 76

The following uses of land may be appropriate within MOL in Lewisham: (a) Private and public open space, playing fields and golf courses; (b) Agriculture, woodlands, (including the creation of new native woodland), and orchards; (c) Rivers canals, reservoirs, lakes and other open water; (d) Allotments and nursery gardens; (e) Cemeteries and associated crematorium; and (f) Nature conservation.

The Council will be supportive of proposals that enhance these uses and will only permit the limited extension of buildings within MOL where this would not result in a disproportionate addition over and above the size of the original building. Improved public access to appropriate land uses in MOL will be acceptable where it does not conflict with other sustainability objectives as set out in CP 21 of the Core Strategy.

OS2 Public Open Space and Urban Green Space (Open Environment)

The Council will resist inappropriate development on the areas of Public Open Space (POS) or Urban Green Space (UGS), as shown on the Proposals Map. Inappropriate development includes: (a) development that would result in the loss of or damage to POS or UGS; and or (b) development that adversely affects the amenity, open character or appearance of the POS or UGS through inappropriate scale.

Development that would result in the loss of or damage to sites that have not been designated as either POS or UGS but are nonetheless valuable locally will also be resisted as inappropriate.

As an exception to the above, some development on POS or UGS maybe permitted if it comprises: (a) small and unobtrusive development that is ancillary to the open space use and enjoyment of the land; or (b) development that facilitates or enhances public access to Urban Green Space; or (c) development that makes provision nearby for replacement open space of equal or better quality and size. In identifying Public Open Space, the following uses should be applied to this policy: Sports and Recreation fields, Burial Spaces, Historic Parks, Gardens and Landscapes and any other space which breaks up the built form.

In exceptional circumstances, the Council may enter into s.106 negotiations to secure off-site provision of open space where no other suitable site can be found.

LDF – Development Policies and Site Allocations, Preferred Options Report 77 OS 3 World Heritage Site Buffer Zone

The Council will give special consideration to developments within the declared World Heritage Site Buffer Zone as delineated on the Proposals Map, that may be visible from within the World Heritage Site. New developments on land within the buffer zone will be required to have no adverse visual impact on and enhance the World Heritage Site affecting the land within the Borough.

Reasons for the Preferred Option

Consistency with national and regional planning guidance PPG 9 seeks to promote sustainable development as well as conserving, enhancing and restoring the diversity of wildlife as well as contributing to urban renaissance. PPG17 focuses on quality improvements to existing Public Open Space and acknowledges that while there is a need to increase the amount of open space in some areas this is not feasible, and in such cases improvements to the quality of open space are also very important.

The London Plan’s objective to “Accommodate London’s growth within its boundaries without encroaching on open spaces” is supported by policies 3D.7 Realising the value of open space, 3D.9 Metropolitan Open Land – where Boroughs should maintain the protection of MOL from inappropriate development, 3D.10 Open Space Provision in UDPs, 3D.11 Open Space Strategies and 3D.12 Biodiversity and nature conservation. Policy 4B.13 seeks to protect and safeguard London’s World Heritage sites.

The East London Sub-Regional Development Framework supports the protection of public open space through Actions 4D and 4E.

Consistency with other Council documents The draft policy is in line with the Council’s adopted Community Strategy which seeks to secure the Council’s objective of sustainable regeneration of Lewisham – its housing, transport and environment.

What alternatives were considered and why were they rejected Responses supported a range of the above options with options 1, 2, 3 and 8 being particularly popular.

The proposed draft policy is a series of policies for considering the protection and enhancement of various types of open spaces as well as avoiding inappropriate development. As such the options have been incorporated into the draft policies, while others such as the reference to developer contributions have been addressed in other sections of the preferred options.

It was considered that Option 4 would be inconsistent with National (PPG17) and Regional (Policy 3D.10 of the London Plan) guidance. It would also not be the most sustainable option.

LDF – Development Policies and Site Allocations, Preferred Options Report 78 Option 6 was considered to be inappropriate and would not conform to government guidance as detailed in planning circular 05/05 ‘planning obligations’. As such, this option cannot be explored.

Option 7 was considered to be too onerous on the remit of the Councils statutory duties. Although some sites cannot be readily accessible to the public, these sites still have an intrinsic value with regard to the visual amenity and character of the environment and may offer habitats to the borough’s wildlife. As such this option was disregarded.

Option 8 was considered to be innovative in its approach to providing more open space for the borough. Brownfield land has been earmarked through National (PPS3) guidance and Regional (Objective 6) policy

3.4.2 Dealing with Open Space Deficiencies

Consultation into what people value most about living in Lewisham has revealed that open space plays a large role in a community’s satisfaction with their living and working environment. As identified in the research for the Borough’s Open Space Strategy and based on the National Playing Fields Association ‘Six Acre Standard’, Lewisham is currently deficient in the amount of open space and accessibility necessary for the growing population, relative to other Borough’s and policy guidance. The issue is therefore what we can do to address the current inadequacies and prevent further loss of this valuable community resource. The Borough has recently been awarded seven Green Flags, ranking it first (with Haringey) within London. This illustrates that not only quantity of open space is important but also the quality and accessibility of those open spaces.

One of the principle roles of the planning system with respect to Open Space is to protect its current use from inappropriate development. The Council recognises its role in ensuring development does not adversely affect the value of existing Open Space and that measures are taken to ensure areas of deficiencies are minimised and remedied.

The Options Three options were put forward as part of the issues and options consultation. 1. The Borough adopts a target of 1.7ha/1000 head of population average of Open Space by 2006 and 1.75ha by 2010 over the whole of the Borough. 2. Borough maintains 1.67ha/1000 head of population average, with no aim to increase. 3. Target of 1.7ha/1000 head of population average of Open Space set over areas of deficiency as defined in UDP maps by 2006 and 1.75ha by 2010.

The Preferred Option The preferred option is to adopt option 2. This option seeks to address concerns from the Open Space needs survey and In light of the proposed GLAs housing target figures, there is a need to ensure that any target rate is within the realms of achievability. The housing target figures are likely to add an additional 20,000 people to the borough over the next 10 years. This increase will have a significant impact on the per capita figures for open space within the Borough. In considering the alternative approaches to open space and the amount of land which is required, the alternative options were not considered feasible, or attainable in

LDF – Development Policies and Site Allocations, Preferred Options Report 79 light of the significant amount of land which would be required to achieve the proposed targets. It is desirable to set a ‘local target’ for the amount of public open space per 1000 head of population. The current level is 1.67ha of POS per 1000 head of population is a realistic target and falls inline with the forecasted increase in the borough population. The radial maps, Figures 5 and 6 illustrate the areas of deficiency for Public Open Space, both at Local (400m) and District park (1200m) levels. In a heavily urbanised inner London Borough such as Lewisham, it is difficult to make provision for new public open space, but not impossible. The Sundermead housing scheme has made it possible to plan for a new town centre park, which on completion, together with the proposed new town centre interchange open space, will reduce the area of deficiency at a Local Park level in the town centre.

LDF – Development Policies and Site Allocations, Preferred Options Report 80 Figure 5. Area of Local Park Deficiency

LDF – Development Policies and Site Allocations, Preferred Options Report 81 Figure 6. Area of District Park Deficiency

LDF – Development Policies and Site Allocations, Preferred Options Report 82 Draft Policy

OS 4 Open space deficiencies

Proposals for large residential schemes will be acceptable in principle, providing that the provision of open space would not fall below 1.67ha/ per 1000 population and would be sited close to public transport links where feasible. If the proposal would be sited in an area of Open Space deficiency or would create an area of deficiency through the development, proposals should provide good quality open space commensurate to the proposed development and its occupiers.

In all major developments there is a requirement to provide public open space. In areas identified as being deficient in Public Open Space and shown on Figures 5 and 6 the Council will concentrate its efforts to negotiate with developers for the provision of new open spaces as part of new housing schemes. In cases where this is not practicable, off site provision to improve existing open space or public access to existing open spaces may be considered as outlined in CP 22 of the Core Strategy.

In pursuant of this policy, planning obligations may be sought to ensure compliance with this policy.

Reasons for the Preferred Option Consistency with national and regional planning guidance PPG17 focuses on quality improvements to existing Public Open Space and acknowledges that while there is a need to increase the amount of open space in some areas this is not feasible, and in such cases improvements to the quality of open space are also very important.

The London Plan’s objective to “Accommodate London’s growth within its boundaries without encroaching on open spaces” is supported by policies 3D.7 Realising the value of open space, 3D.9 Metropolitan Open Land – where Boroughs should maintain the protection of MOL from inappropriate development, 3D.10 Open Space Provision in UDPs, 3D.11 Open Space Strategies and 3D.12 Biodiversity and nature conservation.

The East London Sub-Regional Development Framework supports the protection of public open space through Actions 4D and 4E.

Consistency with other Council Documents The draft policy is in line with the Council’s adopted Community Strategy which seeks to secure the sustainable regeneration of Lewisham – its housing, transport and environment.

What alternatives were considered and why they were rejected Of the 14 responses, 10 were in support of the option to average 1.7ha per 1000 population with an aim to increase this provision. Only one response supported maintaining the existing level of provision, while three supported the option to increase the average in areas of deficiency.

LDF – Development Policies and Site Allocations, Preferred Options Report 83 Option 1 is the current aspiration for Lewisham. However, in order to seek to realistically improve the provision of open space it was considered that this option would not be achievable in its approach and not flexible enough to change with new pressures. As such this option was dismissed.

Option 3 seeks to address the constraints that are experience today but does not take into consideration the fact that areas that are not deficient in open space could become deficient within the plan period. This option proved unsustainable and would not be flexible to deal with changing circumstances. There was very little response to this issue. As such, this option was also dismissed.

3.4.3 Open Space Provision – Quality and Maintenance

Open spaces provide for a large variety of uses. For many, their primary function is to serve the recreational needs of the community. Active and usable open space often requires facilities and structures to support and promote this use, such as toilets, walkways, interpretation material, seating, tables, playgrounds and sports fields. There is also a need for such areas to be located and designed to meet the needs of the community.

It has been widely recognised that improving the state of our parks is vital to delivering an urban renaissance and restoring pride in our neighbourhoods. Lewisham has made a start in the right direction and was awarded seven green flags in 2006. The green flag awards are a measure of the quality of the Borough’s open spaces. Respondents from the open space strategy voted litter bins, dog bins, access for wheelchairs and pushchairs, children’s play areas and toilets as the top five most important facilities in parks and open spaces.

Well designed and managed spaces can help bring communities together, provide a place to meet and recreate. Poor maintenance and management or park spaces on the other hand can deter people from visiting and using and appreciating these spaces. Barriers to participation can include fear of crime/ feeling unsafe, traffic, lack of facilities / things to do, mess (e.g. dog mess and rubbish) and access for all. However, 45% of park users cited fear of crime when specifically asked about the main barrier to visiting local open spaces.

Considering that the borough is deficient in open space provision, it is even more important that the open spaces we actually do have are of the best quality, safe and are made accessible to all who choose to use it. Developments that include housing provision should make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs.

The Options Three options which were put forward as part of the issues and options consultation. 1. Adopting the Actions documented in the Open Space Strategy for Lewisham 2005-2010. 2. Setting quality standards and criteria to assess current situation and priorities for improvements and on-going public consultation to gauge satisfaction with open spaces. 3. In areas of deficiency the Council will not permit development which will adversely affect accessibility to open space. 4. In areas of deficiency the Council will seek section 106 development contributions to improve quality of public open spaces facing the increased pressure.

LDF – Development Policies and Site Allocations, Preferred Options Report 84 The Preferred Option The preferred option is to proceed with a combination of the options but with the main emphasis taken from the recommendations and actions identified in the Open Spaces Strategy for Lewisham 2005 -2010.

Draft Policies

OS 5 Open space quality and maintenance

Proposals for new open space or development on existing open spaces should be of a good quality design which has regard to creating a safe and accessible design and where applicable allow for the creation of habitats for biodiversity purposes. For schemes which involve housing, play and informal recreation facilities should be provided within the scheme. For developments which involve the creation of open space, a landscape and maintenance statement should accompany planning applications.

In pursuant to this the policy, planning obligations may be sought to ensure compliance with this policy.

OS 6 Trees The Council will seek to prevent the loss of trees of amenity and nature conservation value when granting planning permission and, where appropriate, make Tree Preservation Orders for their protection.

Reason for the Preferred Option Consistency with national and regional planning guidance PPG 9 seeks to promote sustainable development, as well as conserving, enhancing and restoring the diversity of wildlife as well as contributing to urban renaissance. PPG17 focuses on quality improvements to existing Public Open Space and acknowledges that while there is a need to increase the amount of open space in some areas this is not feasible, and in such cases improvements to the quality and access of open space are also very important.

The London Plan’s objective to “Accommodate London’s growth within its boundaries without encroaching on open spaces” is supported by policies 3D.7 Realising the value of open space, 3D.9 Metropolitan Open Land – where Boroughs should maintain the protection of MOL from inappropriate development, 3D.10 Open Space Provision in UDPs, 3D.11 Open Space Strategies, providing safe, good quality, well designed, secure and stimulating play and recreation provision is reinforced through policy 3D.11i Children and Young People’s play and Informal recreation strategies and 3D.12 Biodiversity and nature conservation. The Mayor’s London Tree and Woodland Framework objectives are to protect, maintain and enhance trees and woodland.

The East London Sub-Regional Development Framework supports the protection of public open space through Actions 4D and 4E.

Consistency with other Council documents

LDF – Development Policies and Site Allocations, Preferred Options Report 85 The draft policy is in line with the Council’s adopted Community Strategy which seeks to secure the sustainable regeneration of Lewisham – its housing, transport and environment.

What alternatives were considered and why were they rejected There was support for all of the options put forward. In particular support was received for adopting the recommendations and actions of the Open Spaces Strategy for Lewisham 2005-2010.

The preferred policy incorporates all of the proposed options.

The sustainability appraisal indicated that Option 2 proved the most desirable option on an equal par with Issue 1. Although an annual audit of the quality of open spaces is undertaken, a quality standard has not been adopted. Until a standard has been adopted, this option cannot be taken forward.

Option 3 is now covered in Policy OS4 and would be a repetition. As such this option was not considered.

Planning Obligations can only be sought in relation to the planning application it serves and not for the benefit of the Council as a whole. Planning Circular 05/2005 sets out the framework for planning obligations. As such, Option 4 was dismissed.

3.4.4 Protection and Enhancement of Natural Habitats and Biodiversity

Open space areas provide the majority of the Borough’s most significant and whole habitats for flora and fauna species. Open spaces can also provide important linkages between significant ecological sites. When living in such a dense urban environment, it is important that these areas are protected, not only for their intrinsic flora and fauna values, but in recognising that healthy functional ecosystems can contribute to a better quality of life and a sense of well-being for those who live and work in urban areas.

Activities on open space and adjoining areas can potentially result in adverse effects on the environmental qualities of the site. It is therefore important that such activities are managed in such a way that primarily avoids, remedies or mitigates these effects.

Many sites of local nature conservation importance have been given designations by local authorities. These sites often accord people in the community the only opportunity of direct contact with nature. Lewisham has a long tradition of conserving and enhancing its natural environment. The Lewisham Biodiversity Partnership was established in 1999 to develop an action plan for the borough’s wildlife and natural environment and follows current guidance taken from the UK Biodiversity Action Plan, and the Mayor’s Biodiversity Strategy. The partnership aims to bring in local expertise and enthusiasm working towards being at the forefront of local conservation. The document sets out the biodiversity of all plants, animals and species to be promoted and given priority to its longevity.

The Options Six options were put forward as part of the issues and options consultation. 1. Adopt target that the existing 3.5% of public space actively managed as natural habitat should increase to 4.5% by 04/05, 5% by 05/06 and to 5.5% by 06/07.

LDF – Development Policies and Site Allocations, Preferred Options Report 86 2. Subject to other planning considerations, developments seeking to conserve or enhance the biodiversity and geological conservation interests of the area and/or the immediate locality should be permitted. 3. Encourage naturalisation of waterways and esplanade areas in consultation with the Environment Agency. 4. Support for developments using green building methods. 5. Where development will result in adverse impacts on biodiversity and conservation, planning permission for it should only be granted where adequate mitigation measures are put in place. Council will seek appropriate measures to compensate for any harm which cannot be prevented or mitigated. 6. Council will need to be satisfied that any reasonable alternative sites for development have been fully considered.

The Preferred Option The preferred option is to proceed with a combination of options 2, 5 and 6. this was due to the high level of response during the issues and option consultation, these options were sustainable when amalgamated together and the Open Space strategy outlines similar requirements in the Recommendations.

Draft Policy

OS7 Biodiversity

Subject to other planning considerations, developments seeking to conserve or enhance the biodiversity and geological conservation interests of the area and/or the immediate locality should be permitted. The Council will seek : • To protect, manage and enhance biodiversity; • Protection of Sites of Importance for Nature Conservation and Green Corridors; • To resist proposed development which would harm the population or conservation status of protected and priority species; • Biodiversity enhancements in new developments; • Promotion of public access and appreciation of nature; and • A justification that no alternative sites were available to avoid any impact on habitats. Only in this instance will the Council seek appropriate mitigation methods and/or other compensatory tools prior to, during and thereafter for so long as the development remains in existence, where development will cause harm to biodiversity.

Planning obligations may be sought where proposals would have a direct impact on sites near or within a site of importance for nature conservation.

Reasons for the Preferred Option Consistency with National and regional planning policy PPG 9 seeks to promote sustainable development, as well as conserving, enhancing and restoring the diversity of wildlife as well as contributing to urban renaissance.

LDF – Development Policies and Site Allocations, Preferred Options Report 87 The London Plan requires the protection and the improvement of access to nature on the strategic network of land for biodiversity (policy 3D.12), which is reflected in the wildlife sites protected in the Lewisham UDP (see figure 7). This network serves to protect nature for its own sake and to maintain and improve access to nature for Lewisham’s residents.

The East London Sub-Regional Development Framework supports the protection of public open space through Actions 4D and 4E.

Consistency with other Council documents The draft policy is in line with the Council’s adopted Community Strategy which seeks to secure the sustainable regeneration of Lewisham– its housing, transport and environment, to sustain and improve the health and wellbeing of local people and also improve the effectiveness, efficiency and sustainability of local public services; optimise investment in infrastructure and improve the management of assets.

The Council is currently in the process of preparing a Biodiversity Action Plan for the borough and it is anticipated that ‘A Natural Renaissance for Lewisham’ will be consulted upon in the near future. However, in preparation of the Preferred Option consideration has been given to the initial draft document and the stated objectives for biodiversity within the Borough.

What alternatives were considered and why they were rejected There was support for all of the options put forward. In particular support was received for adopting the recommendations and actions of the Open Spaces Strategy for Lewisham 2005-2010.

The preferred policy incorporates all of the proposed options.

Although, the aspiration for this policy was included within the final development control policy, it was deemed very difficult to be able to monitor this policy. As such, Option 1 was dismissed.

Option 3 is covered in OS8 and as such is not included within this issue

Option 4 is covered in a cross cutting issue and is featured within the Spatial (Core) policies. Therefore it was considered a repetition and not needed as a development control policy.

3.4.5 Protection and Enhancement of Open Space Links and Corridors

Open spaces can provide important linkages between significant ecological sites. Such linkages serve to enhance ecosystem connectivity and the biodiversity of an area by providing wildlife corridors that encourage movement of plants and animals between ecological sites and into the urban environment. Such linkages need to be carefully managed and of a sufficient width to serve their purpose.

Activities on land adjoining these areas can potentially dilute the environmental qualities and effectiveness of links and corridors. It is therefore important that such activities are managed in such a way that avoids, remedies or mitigates these effects. Links and corridors can also provide unique and valuable recreational opportunities for the community and public as a whole, while providing participants an opportunity to experience a more natural environment

LDF – Development Policies and Site Allocations, Preferred Options Report 88 over a decent length journey. An example of this in the London Borough of Lewisham is the high-use South East London Green Chain, most of which is protected as MOL. The Council will actively embrace the Green Grid principles as set out in the East London Sub- Regional Development Framework and the draft Further Alterations to the London Plan in order to secure further improvements to the Borough’s open space network.

Lewisham’s rivers (a short section of the Thames, and longer stretches of the Ravensbourne and its tributaries the Pool, Quaggy and Spring Brook) provide important linear features which can form the basis for wildlife corridors, as well as the Waterlink Way (see policy OS 9) and the Thames path (see Policy U 28), and are important to sustain biodiversity. In line with the Blue Ribbon Network, all development on or adjacent to the Blue Ribbon Network must respect its water location and should particularly include a mix of uses appropriate to the water space including public use open spaces. The Council considers that buffer zones around watercourses can help to maintain the character of rivers and provide refuges for wildlife, as well as pleasant and practical recreational routes. Any proposals should also consider the objectives of the EU Water Framework Directive (Directive 2000/60/EC) which seeks to deliver long term protection of the water environment and the improvement of ground and surface water quality.

The Options Three options were put forward as part of the issues and options consultation. 1. Where development will result in adverse impacts on links identified in the UDP maps, planning permission for it should only be granted where adequate mitigation measures are put in place. Council will seek appropriate measures to compensate for any harm which cannot be prevented or mitigated. 2. Council will only permit development in areas identified in the planning proposal maps as ‘Waterlink Way’ or Green Chain if it enhances the biodiversity or recreational use of the links. 3. Council will encourage proposals for naturalisation of waterways in conjunction with the Environment Agency.

The Preferred Option The preferred option is a combination of the three options which were put forward as part of the issues and options consultation exercise.

Draft Policies

OS 8 South East London Green Chain

The main opens spaces that form the South East London Green Chain are protected as MOL. These spaces will be promoted and managed in order to enhance their role as a local and regional outdoor recreational resource. The Council will explore any ways that could strengthen the role of the SELGC within the borough.

OS 9 River Corridors and the Waterlink Way

LDF – Development Policies and Site Allocations, Preferred Options Report 89 The Council will safeguard the Rivers and the proposed route of the Waterlink Way as shown on the Proposals Map. It will seek the reduction of impact on the natural environment and habitats by the most acceptable route. Through agreements with developers of sites within and adjoining the route some or all of the following elements, as appropriate, will be achieved: (a) to provide additional open space; (b) to improve the quality of the open spaces in Waterlink Way and the links between them, notably footpaths and cycleways; (c) to improve the course and appearance of the waterways and public access to them for passive and active recreation; (d) to create wildlife habitats and to enhance the existing nature conservation value of the waterways. (e) to ensure that a minimum buffer zone of 8 metres where feasible, of reserved soft landscaped land is maintained alongside the river confluence.

The Council will, where appropriate, protect land within and adjacent to River Corridors and the Waterlink Way by seeking planning obligations where development would compromise its strategic role.

OS 10 Green Corridors

The Green Corridors identified on the Proposals Map are protected for their nature conservation and informal recreation value. Planning Permission will only be granted for developments within Green Corridors that enhance these roles.

Planning obligations may be sought where proposals would have a direct impact on sites near or within an identified green corridor. Reasons for the Preferred Option Consistency with national and regional planning guidance The proposed draft policy is specifically supported by the following London Plan Policy, 3D.12 relating to biodiversity and nature conservation. The GLA has also produced a ‘Best Practice Guidance: Development plan policies for Biodiversity’, which steers Local Planning Authorities in determining policies addressing biodiversity and nature conservation.

Consistency with other Council documents The Council is currently in the process of preparing a Biodiversity Action Plan and it is anticipated that ‘A Natural Renaissance for Lewisham’ will be consulted upon in the near future. However, in preparation of the Preferred Option consideration has been given to the initial draft document and the stated objectives for biodiversity within the Borough.

What alternatives were considered and why there were rejected Responses supported for all 3 options. The alternative options incorporate aspects of all the options provided in the Issues and Options document.

LDF – Development Policies and Site Allocations, Preferred Options Report 90 Figure 7. Sites of Nature Conservation Deficiency

LDF – Development Policies and Site Allocations, Preferred Options Report 91